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Rating Action:

Moody's Downgrades 552 RMBS IO Classes and Upgrades 119 RMBS IO Classes from 484 US RMBS Deals following the Implementation of Updated Structured Finance Interest-Only Methodology

09 Jun 2017

New York, June 09, 2017 -- Moody's Investors Service has downgraded the ratings of 552 Interest-Only (IO) bonds and upgraded the ratings of 119 IO bonds backed by US residential mortgage-backed bonds or collateral pools backed by US residential mortgage loans (RMBS), from 484 RMBS transactions issued by multiple issuers. The rating actions result from the adoption of an updated approach to rating interest-only securities; some of today's actions also reflect the correction of errors, as further described below. The rating downgrades average between 1 and 2 notches whereas the upgrades average 1 notch.

Please click on the following link to access the full list of affected credit ratings. This list is an integral part of this press release and identifies each affected rating, as well as factors driving each rating action and the methodologies used.

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF453777

RATINGS RATIONALE

Today's rating actions follow the publication of "Moody's Approach to Rating Structured Finance Interest-Only (IO) Securities" published on 8 June 2017 (the "updated IO methodology") and reflect the rating impact of our updated approach incorporating performance information as of the April 2017 remittance date.

Please click on this link http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF453777 for the List of Affected Credit Ratings. This list is an integral part of this Press Release and provides, for each of the credit ratings covered, Moody's disclosures on the following items:

-Principal Methodologies

The updated IO methodology modifies Moody's approach to rating IO securities referencing multiple bonds and single or multiple collateral pools with realized losses. References made to the exclusion of certain IO securities in the previous methodology were removed. In addition, a description was added to explain when an IO bond is treated as having effectively matured and results in the withdrawal of the rating. The updated IO methodology explains that Moody's will limit the rating of an IO security to no more than 5 notches above the rating of the lowest credit quality reference bond or rating that would be assigned based on the assessment of the default probability of the reference pool(s), as applicable, and clarifies that the collateral pool's default probability typically will be treated as equivalent to a Ca(sf) if a loss is expected on the pool. The updated IO methodology also explains that Moody's 10-year Idealised Cumulative Expected Loss Rates table will be used to determine the rating of the IOs referencing multiple bonds and IOs backed by single or multiple pools as well as how the table is used when the loss level falls between two rating categories.

This press release is not intended to provide a summary of the updated IO methodology. For a full explanation of the methodology, please consult the updated report, now available on www.moodys.com and accessible at: https://www.moodys.com/research/Moodys-updates-its-approach-for-rating-structured-finance-interest-only--PR_367970

Today's rating action includes 85 IO PO bonds. IO PO bonds have two components, one being an IO component and the other a principal-only (PO) component. The rating of the IO PO bonds is the weighted average (using Moody's 10-year Idealised Cumulative Expected Loss Rates table) of the IO component rating, based on the updated IO methodology, and the PO component rating, based on the "US RMBS Surveillance Methodology," published on 31 January 2017.

In applying the updated IO methodology, we discovered an error in a number of IO ratings assigned under the prior version of the IO rating methodology, "Moody's Approach to Rating Structured Finance Interest-Only Securities," published on 20 October 2015 ("prior IO methodology"). Under the prior IO methodology, the ratings of certain IOs -- those referencing multiple bonds, or single or multiple pools -- were determined by mapping either the weighted average factor (WARF) of the bonds, or the expected loss (EL) of the pool(s), to a rating using a table. For 301 of the bonds in today's rating action, the mapping in prior rating actions was incorrect, resulting in the assignment of ratings 1 to 2 notches lower than called for under the proper mapping. Today's action on these bonds reflects the correction of the mapping error, the upward impact of which correction was offset in some cases by the downward impact of the updated IO methodology.

In addition to the mapping error, today's rating action also includes the correction of other errors on 29 IO bonds, as described below.

The ratings of 12 IO bonds were incorrectly linked to the wrong bond(s) or pool(s) in prior rating actions. These errors have been corrected, and today's rating action reflects the appropriate linkage of each such IO bond to its proper reference bond(s) or pool(s), as well as the application of the updated IO methodology.

The ratings of 6 IO bonds were not contemporaneously updated to reflect changes in the rating of their referenced bonds. In prior rating actions, the rating(s) of the reference bonds were updated but we did not make the corresponding change to the rating of the linked IO. Today's rating action corrects these errors and also applies the updated IO methodology to these IO bonds.

The ratings of 6 IO bonds used incorrect inputs into the calculation of the weighted average rating factor under the prior IO methodology. Today's rating action corrects these input errors and applies the updated IO methodology to these IO bonds.

The ratings of 5 IO PO bonds did not reflect the application of the prior IO rating methodology for the interest-only component. Today's rating action applies the updated IO methodology to the IO component of these IO PO bonds.

In addition, there are 1133 IO bond ratings that may, in the past, have been subject to the mapping error described above, but which are not part of today's rating action because their current ratings are appropriately positioned under the updated IO methodology. We are reviewing these 1133 IO bonds to determine whether they were subject to the mapping error in earlier actions, and we will communicate our findings to the market as a matter of transparency.

A list of these 1133 IO bonds may be found at:

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF453776

Regardless of our findings, the ratings of these 1133 IO bonds are not expected to change because the ratings are appropriately positioned under the updated IO methodology.

Factors that can lead to an upgrade or downgrade of the ratings:

An IO bond may be upgraded or downgraded, within the constraints and provisions of the updated IO methodology, based on lower or higher realized and expected loss due to an overall improvement or decline in the credit quality of the reference bonds and/or pools.

For more information please see www.moodys.com.

REGULATORY DISCLOSURES

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions of the disclosure form.

The analysis includes an assessment of collateral characteristics and performance to determine the expected collateral loss or a range of expected collateral losses or cash flows to the rated instruments. As a second step, Moody's estimates expected collateral losses or cash flows using a quantitative tool that takes into account credit enhancement, loss allocation and other structural features, to derive the expected loss for each rated instrument.

Moody's quantitative analysis entails an evaluation of scenarios that stress factors contributing to sensitivity of ratings and take into account the likelihood of severe collateral losses or impaired cash flows. Moody's weights the impact on the rated instruments based on its assumptions of the likelihood of the events in such scenarios occurring.

For ratings issued on a program, series or category/class of debt, this announcement provides certain 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 certain regulatory disclosures in relation to the credit rating action on the support provider and in relation to each particular credit rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides certain 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.

For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit rating action, the associated regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.

Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.

The below contact information is provided for information purposes only. Please see the ratings tab of the issuer page at www.moodys.com, for each of the ratings covered, Moody's disclosures on the lead rating analyst and the Moody's legal entity that has issued the ratings.

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.

Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosures for each credit rating.

Soumya Vasudevan
Asst Vice President - Analyst
Structured Finance Group
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

Youriy Koudinov
VP - Sr Credit Officer/Manager
Structured Finance Group
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

Releasing Office:
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653

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