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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.​​​

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Related Issuers
ABFC Asset-Backed Certificates, Series 2006-HE1
ACE Securities Corp. Home Equity Loan Trust, Series 2006-OP1
ACE Securities Corp. Home Equity Loan Trust, Series 2006-OP2
American Home Mortgage Assets Trust 2005-2
American Home Mortgage Assets Trust 2006-1
American Home Mortgage Assets Trust 2006-2
American Home Mortgage Assets Trust 2006-4
American Home Mortgage Assets Trust 2006-5
American Home Mortgage Assets Trust 2006-6
American Home Mortgage Assets Trust 2007-2
American Home Mortgage Assets Trust 2007-5
American Home Mortgage Assets Trust 2007-SD2
American Home Mortgage Investment Tr 2006-3
American Home Mortgage Investment Trust 2005-SD1
American Home Mortgage Investment Trust 2006-1
American Home Mortgage Investment Trust 2007-1
American Home Mortgage Investment Trust 2007-2
American Home Mortgage Investment Trust 2007-A
American Home Mortgage Investment Trust 2007-SD1
Ameriquest Mortgage Securities Inc. Series 2001-2
Ameriquest Mortgage Securities Inc., 2002-4
Ameriquest Mortgage Securities Inc., Quest Trust 2005-X2
Ameriquest Mortgage Securities Inc., Series 2002-2
Ameriquest Mortgage Securities Inc., Series 2002-3
Ameriquest Mortgage Securities Inc., Series 2002-AR1
Ameriquest Mortgage Securities Inc., Series 2003-AR1
Ameriquest Mortgage Securities Inc., Series 2003-AR2
Amortizing Residential Collateral Trust 2002-BC9
Amortizing Residential Collateral Trust Mortgage Pass-Through Certificates, Series 2002-BC2
Amortizing Residential Collateral Trust, Series 2002-BC3
Argent Mortgage Loan Trust 2005-W1
Argent Securities Trust 2006-M1
Argent Securities Trust 2006-M2
Argent Securities Trust 2006-W2
Argent Securities Trust 2006-W3
Argent Securities Trust 2006-W4
Argent Securities Trust 2006-W5
Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT1
Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT2
Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT3
Asset Backed Securities Corporation Home Equity Loan Trust, Series 2001-HE1
First Franklin Mortgage Loan Trust 2001-FF2, Asset-Backed Certificates, Series 2001-FF2
HarborView Mortgage Loan Trust 2006-14
HarborView Mortgage Loan Trust 2007-2
HarborView Mortgage Loan Trust 2007-5
HarborView Mortgage Loan Trust 2007-6
Morgan Stanley Dean Witter Capital I Inc. Trust 2002-OP1
Option One Mortgage Loan Trust 2006-2
Option One Mortgage Loan Trust 2006-3
Option One Mortgage Loan Trust 2007-1
Option One Mortgage Loan Trust 2007-2
Option One Mortgage Loan Trust 2007-3
Option One Mortgage Loan Trust 2007-4
Option One Mortgage Loan Trust 2007-5
Option One Mortgage Loan Trust 2007-CP1
Option One Mortgage Loan Trust 2007-FXD2
Quest Trust 2006-X2
SASCO Mortgage Loan Trust 2003-GEL1
SG Mortgage Securities Trust 2006-OPT2
Soundview Home Loan Trust 2006-OPT4
Soundview Home Loan Trust 2007-OPT1
Soundview Home Loan Trust 2007-OPT3
Soundview Home Loan Trust 2007-OPT4
Soundview Home Loan Trust 2007-OPT5
Structured Asset Investment Loan Trust 2003-BC11
Structured Asset Investment Loan Trust 2003-BC2
Structured Asset Investment Loan Trust 2003-BC5
Structured Asset Investment Loan Trust 2003-BC6
Structured Asset Investment Loan Trust 2004-10
Structured Asset Investment Loan Trust 2004-2
Structured Asset Investment Loan Trust 2004-4
Structured Asset Investment Loan Trust 2004-7
Structured Asset Investment Loan Trust 2005-1
Structured Asset Investment Loan Trust 2005-10
Structured Asset Investment Loan Trust 2005-11
Structured Asset Investment Loan Trust 2005-7
Structured Asset Investment Loan Trust 2006-2
Structured Asset Investment Loan Trust 2006-BNC3
Structured Asset Securities Corp 2006-Z
Structured Asset Securities Corp Trust 2005-S5
Structured Asset Securities Corp Trust 2005-S7
Structured Asset Securities Corp Trust 2006-BC2
Structured Asset Securities Corp., Amortizing Residential Collateral Trust 2001-BC1
Structured Asset Securities Corporation 2005-GEL4
Structured Asset Securities Corporation 2005-S1
Structured Asset Securities Corporation 2006-GEL3
Structured Asset Securities Corporation 2007-GEL2
Announcement:

Moody's: Servicing transfer to Ocwen Loan Servicing,LLC from Homeward Residential, Inc. has no negative ratings impact on Eighty Seven US RMBS transactions

22 Mar 2013

New York, March 22, 2013 -- Moody's Investors Service ("Moody's") stated today that Ocwen Loan Servicing,LLC's ("Ocwen") purchase of the servicing rights to the affected transactions listed below from Homeward Residential, Inc. ("Homeward") will not, in and of itself and at this time, result in a reduction or withdrawal of the current ratings of the securities issued by the affected transactions.

Affected Transactions:

Subprime Collateral

ABFC Asset-Backed Certificates, Series 2006-HE1

ACE Securities Corp. Home Equity Loan Trust, Series 2006-OP1

ACE Securities Corp. Home Equity Loan Trust, Series 2006-OP2

American Home Mortgage Assets Trust 2007-SD2

American Home Mortgage Investment Trust 2007-SD1

Ameriquest Mortgage Securities Inc. Series 2001-2

Ameriquest Mortgage Securities Inc., 2002-4

Ameriquest Mortgage Securities Inc., Quest Trust 2005-X2

Ameriquest Mortgage Securities Inc., Series 2002-2

Ameriquest Mortgage Securities Inc., Series 2002-3

Ameriquest Mortgage Securities Inc., Series 2002-AR1

Ameriquest Mortgage Securities Inc., Series 2003-AR1

Ameriquest Mortgage Securities Inc., Series 2003-AR2

Argent Mortgage Loan Trust 2005-W1

Argent Securities Trust 2006-M1

Argent Securities Trust 2006-M2

Argent Securities Trust 2006-W2

Argent Securities Trust 2006-W3

Argent Securities Trust 2006-W4

Argent Securities Trust 2006-W5

Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT1

Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT2

Asset Backed Funding Corporation Asset-Backed Certificates, Series 2006-OPT3

First Franklin Mortgage Loan Trust 2001-FF2, Asset-Backed Certificates, Series 2001-FF2

Morgan Stanley Dean Witter Capital I Inc. Trust 2002-OP1

Option One Mortgage Loan Trust 2006-2

Option One Mortgage Loan Trust 2006-3

Option One Mortgage Loan Trust 2007-1

Option One Mortgage Loan Trust 2007-2

Option One Mortgage Loan Trust 2007-3

Option One Mortgage Loan Trust 2007-4

Option One Mortgage Loan Trust 2007-5

Option One Mortgage Loan Trust 2007-CP1

Option One Mortgage Loan Trust 2007-FXD2

Quest Trust 2006-X2

SG Mortgage Securities Trust 2006-OPT2

Soundview Home Loan Trust 2006-OPT4

Soundview Home Loan Trust 2007-OPT1

Soundview Home Loan Trust 2007-OPT3

Soundview Home Loan Trust 2007-OPT4

Soundview Home Loan Trust 2007-OPT5

Structured Asset Investment Loan Trust 2003-BC11

Structured Asset Investment Loan Trust 2003-BC2

Structured Asset Investment Loan Trust 2003-BC6

Structured Asset Investment Loan Trust 2004-2

Structured Asset Investment Loan Trust 2004-4

Structured Asset Investment Loan Trust 2004-7

Structured Asset Investment Loan Trust 2006-BNC3

Structured Asset Securities Corp 2006-Z

Structured Asset Securities Corp Trust 2006-BC2

Structured Asset Securities Corp., Amortizing Residential Collateral Trust 2001-BC1

Alt-A Collateral

American Home Mortgage Assets Trust 2005-2

American Home Mortgage Assets Trust 2006-1

American Home Mortgage Assets Trust 2006-2

American Home Mortgage Assets Trust 2006-4

American Home Mortgage Assets Trust 2006-5

American Home Mortgage Assets Trust 2006-6

American Home Mortgage Assets Trust 2007-2

American Home Mortgage Assets Trust 2007-5

American Home Mortgage Investment Trust 2006-1

American Home Mortgage Investment Tr 2006-3

American Home Mortgage Investment Trust 2007-1

American Home Mortgage Investment Trust 2007-2

HarborView Mortgage Loan Trust 2006-14

HarborView Mortgage Loan Trust 2007-2

American Home Mortgage Investment Trust 2007-A

HarborView Mortgage Loan Trust 2007-5

Closed End Second Lien Collateral

American Home Mortgage Investment Trust 2005-SD1

Structured Asset Securities Corporation 2005-S1

Structured Asset Securities Corp Trust 2005-S5

Structured Asset Securities Corp Trust 2005-S7

Affected Transactions with less than 5% of loans transferred:

Subprime Collateral

Amortizing Residential Collateral Trust 2002-BC9

Amortizing Residential Collateral Trust Mortgage Pass-Through Certificates, Series 2002-BC2

Amortizing Residential Collateral Trust, Series 2002-BC3

Asset Backed Securities Corporation Home Equity Loan Trust, Series 2001-HE1

SASCO Mortgage Loan Trust 2003-GEL1

Structured Asset Investment Loan Trust 2003-BC5

Structured Asset Investment Loan Trust 2004-10

Structured Asset Investment Loan Trust 2005-1

Structured Asset Investment Loan Trust 2005-10

Structured Asset Investment Loan Trust 2005-11

Structured Asset Investment Loan Trust 2005-7

Structured Asset Investment Loan Trust 2006-2

Structured Asset Securities Corporation 2005-GEL4

Structured Asset Securities Corporation 2006-GEL3

Structured Asset Securities Corporation 2007-GEL2

Alt-A Collateral

HarborView Mortgage Loan Trust 2007-6

Homeward Residential, Inc. ("Homeward") has requested that Moody's provide its opinion on whether the ratings on the securities issued by the affected transactions would be downgraded or withdrawn as a result of the transactions having their servicing rights transferred to Ocwen from Homeward. The transfer of the servicing of the mortgage loans is expected to be completed by March 31, 2013.

In determining the credit impact of the transfer of servicing to Ocwen, Moody's reviewed i) Ocwen's servicing metrics ii) the affected transactions' sensitivity to cash flow disruptions due to changes in servicing and modification practices, and iii) Ocwen's ability to handle the proposed transfer.

Moody's view is based primarily on its opinion that the performance of each of the securities in the affected transactions will not have material negative implication following changes in servicing strategy that can occur after transfer of servicing rights. Ocwen is rated SQ2- as a primary servicer of subprime residential mortgage loans and as a special servicer of residential mortgage loans. Both servicer quality assessments are on review for possible downgrade.

Moody's opinion addresses only the current impact on Moody's ratings, and we do not express an opinion as to whether the transfer of servicing rights has or could have any other effects that investors may or may not view positively.

The methodology used in assessing the credit impact of the servicing transfer was "Moody's Approach to Rating Residential Mortgage Servicers" published in January 2001. Other methodologies include "Updated Moody's Servicer Quality Rating Scale and Definitions" published in May 2005, "Proposal to Update Moody's Approach To Servicer Quality (SQ) Assessment For U.S. Primary Residential Mortgage Servicers" published in July 2012, " 2005-2008 US RMBS Surveillance Methodology" published in July 2011, "Pre-2005 US RMBS Surveillance Methodology" published in January 2012, "US RMBS Surveillance Methodology for Scratch and Dent" published in May 2011, and "Second Lien RMBS Loss Projection Methodology" published in April 2010. Please see the Credit Policy page on www.moodys.com for a copy of these methodologies.

Ilana J Fried
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

Deepika Kothari
Vice President - Senior Analyst
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: Servicing transfer to Ocwen Loan Servicing,LLC from Homeward Residential, Inc. has no negative ratings impact on Eighty Seven US RMBS transactions
No Related Data.
© 2019 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 OR IMPAIRMENT. SEE MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S RATINGS. 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 CREDIT 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 ratings opinions and services rendered by it fees ranging from $1,000 to approximately $2,700,000. 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.

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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