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Related Issuers
PLC Capital Trust III
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West Coast Life Insurance Company
Rating Action:

Moody's affirms Protective Life (senior debt at Baa2); stable outlook

15 Jun 2010

Approximately $4.4 billion of securities affected

New York, June 15, 2010 -- Moody's Investors Service today affirmed the debt ratings of Protective Life Corporation (Protective; NYSE: PL; senior debt at Baa2) and the A2 insurance financial strength (IFS) rating of its operating subsidiaries, and changed the outlook to stable from negative.

Moody's said that the affirmation of Protective's ratings and the change in outlook to stable were driven by the improvement in the company's financial flexibility, a stronger regulatory capital position, anticipated recovery in earnings as investment losses subside, and better operating company liquidity stemming from an improved unrealized loss position.

Commenting on the rating affirmation and stable outlook, Moody's Vice President and Senior Credit Officer, Ann Perry said, "During the last year, Protective has taken a number of steps that have strengthened its financial profile. Protective's actions have included raising about $133 million in new capital, improving the capital position of its operating life insurance companies through capital injections, and securing long-term funding for additional regulatory reserves required for its term life business." The rating agency also noted that Protective's business profile remains sound as demonstrated by its good first quarter 2010 sales.

Moody's said Protective's ratings also reflect the company's diverse revenue and earnings sources, multiple distribution channels, good holding company liquidity, and an established core competency in acquiring other companies and blocks of business. According to the rating agency, Protective's unrealized loss position significantly improved since early 2009, and investment losses have lessened and are expected to continue to decrease throughout the remainder of 2010. Protective also has no short-term debt outstanding, and its next significant debt maturity is $250 million due in 2013.

However, Moody's said that Protective still faces challenges in light of a continuing weak economy and the pressure that a stress scenario could place on its earnings and regulatory capital. In a stress scenario, the potential for investment losses in its commercial mortgage portfolio and its non-agency RMBS holdings could strain the company's capital position.

The rating agency also noted that Protective's business mix constrains capital as it must manage the capital strain associated with the expected growth in the amount of regulatory reserves related to Protective's existing book of level premium term insurance and universal life insurance with no-lapse guarantees. Although Protective plans to self-finance these reserves, earnings and capital pressures could make this more difficult, especially under a stress scenario.

Moody's said that the following would place upward pressure on Protective's ratings: 1) investment losses of less than $125 million pre-tax in 2010 ; 2) NAIC RBC ratio at Protective's lead operating company, Protective Life Insurance Company, remains above 350% ; 3) adjusted financial leverage maintained in the mid 20% range; and 4) annual cash flow interest coverage of above 6 times.

The rating agency noted that a downgrade could occur if: 1) investment losses (OTTI and capital losses) exceed $250 million pre-tax in 2010; 2) strain on capital due to regulatory reserve requirements for term insurance and universal life with secondary guarantees; 3) NAIC RBC ratio at Protective Life Insurance Company falls below 300%; 4) adjusted financial leverage rises above 30%; and 5) annual cash flow interest coverage falls below 4 times.

The following ratings were affirmed with a stable outlook:

Protective Life Corporation -- senior unsecured debt at Baa2; senior unsecured shelf at (P)Baa2; subordinated shelf at (P)Baa3; preferred shelf at (P)Ba1; junior preferred shelf at (P)Ba1; capital securities at Ba1;

Protective Life Insurance Co. -- insurance financial strength at A2; short-term insurance financial strength at Prime-1;

West Coast Life Insurance Co. -- insurance financial strength at A2;

PLC Capital Trusts III-V -- trust preferred at Baa3;

PLC Capital Trusts VI-VIII -- trust preferred shelf at (P)Baa3;

Protective Life Secured Trusts -- senior secured at A2;

Protective Life U.S. Funding Trusts -- senior secured at A2;

Protective Life Insurance Company -- Premium Asset Trust Series 2003-10 at A2.

General Repackaging ACES SPC 2006-1, General Repackaging ACES SPC 2007-1 -- funding agreement-backed senior secured debt rating at A2.

On March 31, 2010, the company reported total consolidated GAAP assets of approximately $43.6 billion and shareholders' equity of about $2.8 billion.

Moody's last rating action on Protective was on October 8, 2009 when the rating agency assigned a Baa2 (negative outlook) debt rating to $100 million of senior notes issued by Protective.

The principal methodology used in rating Protective was "Moody's Global Rating Methodology for Life Insurers," which can be found at www.moodys.com in the Rating Methodologies sub-directory under the Research & Ratings tab. Other methodologies and factors that may have been considered in the process of rating PL can also be found in the Rating Methodologies sub-directory on Moody's website.

Moody's insurance financial strength ratings are opinions of the ability of insurance companies to pay punctually senior policyholder claims and obligations.

Visit Moody's website at www.moodys.com/insurance for more information.

New York
Ann G. Perry
VP - Senior Credit Officer
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

New York
Robert Riegel
Managing Director
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's affirms Protective Life (senior debt at Baa2); stable outlook
No Related Data.
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