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Rating Action:

Moody's assigns Counterparty Risk Ratings to 16 Vietnamese banks

18 Jun 2018

Singapore, June 18, 2018 -- Moody's Investors Service has today assigned Counterparty Risk Ratings (CRRs) to 16 rated banks in Vietnam.

The banks affected are: 1) An Binh Commercial Joint Stock Bank (ABB), 2) Asia Commercial Bank (ACB), 3) Ho Chi Minh City Development Joint Stock Commercial Bank (HDBank), 4) JSC Bank for Foreign Trade of Vietnam (Vietcombank), 5) Joint Stock Commercial Bank for Investment and Development of Vietnam (BIDV), 6) Lien Viet Post Joint Stock Commercial Bank (Lien Viet), 7) Military Commercial Joint Stock Bank (Military Bank), 8) Orient Commercial Joint Stock Bank (OCB), 9) Saigon - Hanoi Commercial Joint Stock Bank (SHB), 10) Saigon Thuong Tin Commercial Joint-Stock Bank (Sacombank), 11) Tien Phong Commercial Joint Stock Bank (TPBank), 12) Vietnam International Bank (VIB), 13) Vietnam Joint-Stock Commercial Bank for Industry and Trade (VietinBank), 14) Vietnam Maritime Commercial Joint Stock Bank (MSB), 15) Vietnam Prosperity Joint Stock Commercial Bank (VP Bank), and 16) Vietnam Technological and Commercial Joint Stock Bank (Techcombank). The full list of assigned ratings is provided at the end of this press release.

Moody's Counterparty Risk Ratings are opinions of the ability of entities to honour the uncollateralized portion of non-debt counterparty financial liabilities (CRR liabilities) and also reflect the expected financial losses in the event such liabilities are not honoured. CRR liabilities typically relate to transactions with unrelated parties. Examples of CRR liabilities include the uncollateralized portion of payables arising from derivatives transactions and the uncollateralized portion of liabilities under sale and repurchase agreements. CRRs are not applicable to funding commitments or other obligations associated with covered bonds, letters of credit, guarantees, servicer and trustee obligations, and other similar obligations that arise from a bank performing its essential operating functions.

RATINGS RATIONALE

The CRRs assigned to the 16 rated Vietnamese banks are in line with the Counterparty Risk Assessments (CRA) already assigned.

Because Moody's considers Vietnam not to have an operational resolution regime, in assigning CRRs to the Vietnamese banks subject to this rating action, the rating agency applies its basic Loss Given Failure (LGF) approach. Moody's basic LGF analysis positions CRRs in line with the banks' CRAs, one notch above their adjusted BCAs, prior to government support.

Furthermore, the CRRs also incorporate between zero and one notch of uplift due to Moody's assessment of government support for the 16 banks in times of need, based on the banks' systemic importance to Vietnam. The uplifts are in line with that applied to the CRAs.

OUTLOOK

CRRs do not carry outlooks.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE

ABB - WHAT COULD CHANGE THE RATING UP

Substantial improvements in asset quality and core capital metrics will be positive for the BCA. If the sovereign rating of Vietnam is upgraded, Moody's will consider upgrading the long-term ratings of the bank by possibly incorporating some government support uplift in the ratings.

ABB - WHAT COULD CHANGE THE RATING DOWN

The ratings could be downgraded, if the bank's asset quality deteriorates such that credit losses almost fully deplete its loss absorbing buffers. A significant deterioration in its liquidity metrics could also be negative for the ratings.

A large appetite for credit growth -- in particular, if the growth is at levels materially higher than the system average -- could translate into downward rating actions, or a change in the ratings outlook.

ACB - WHAT COULD CHANGE THE RATING UP

Moody's will consider upgrading the long-term ratings of ACB if (1) Vietnam's sovereign rating is upgraded and (2) the bank posts improved standalone credit metrics that lead to a higher BCA.

Moody's could upgrade ACB's BCA if the macroeconomic and operating conditions for banks in Vietnam improve, leading to a higher Macro Profile for the country.

ACB - WHAT COULD CHANGE THE RATING DOWN

Moody's could downgrade ACB's BCA and ratings if (1) the bank demonstrates a material deterioration in its capital adequacy, or (2) the operating environment deteriorates significantly, against the backdrop of a loosening in the bank's underwriting practices, thereby exposing it to asset-quality risks.

HDBANK - WHAT COULD CHANGE THE RATING UP

Moody's will consider raising HDBank's BCA if the bank's problem loan ratio falls below 4% and its ratio of tangible common equity to adjusted risk-weighted assets, or the TCE ratio, exceeds 10%.

An upgrade of the Macro Profile of Vietnam's banking system, which is currently Weak, would also prove to be positive for HDBank's BCA.

The long-term ratings could be upgraded if the bank's BCA is raised or Vietnam's sovereign rating is upgraded.

HDBANK - WHAT COULD CHANGE THE RATING DOWN

The ratings could be downgraded if HDBank's (1) problem loan ratio rises above 10%, or (2) TCE ratio drops significantly. The ratings are also sensitive to a significant weakening in the bank's liquidity profile.

The ratings could be downgraded if the government's rating is lowered or if Vietnam's Macro Profile is revised downward.

VIETCOMBANK - WHAT COULD CHANGE THE RATING UP

Vietcombank's long-term ratings could be upgraded if Vietnam's sovereign rating is upgraded.

VIETCOMBANK - WHAT COULD CHANGE THE RATING DOWN

Downward pressure on the BCA could develop as a result of (1) a sharp deterioration in the bank's asset quality, and (2) credit growth that significantly lowers its capital levels.

Weaker links with the government, such as a material decrease in the State Bank of Vietnam's ownership stake in the bank, could place downward pressure on the ratings.

BIDV - WHAT COULD CHANGE THE RATING UP

If the B1 rating on the Vietnam government is upgraded, Moody's will likely upgrade the long-term ratings of BIDV, by incorporating additional notches of government support uplift.

The following factors could result in an upward revision of BIDV's BCA: (1) material improvements in asset quality and core capital levels, and (2) significantly lower credit risk concentration to individual borrowers and industry groups.

BIDV - WHAT COULD CHANGE THE RATING DOWN

BIDV's BCA and, consequently, its ratings could be downgraded if (1) the operating environment weakens significantly or underwriting practices become loose, resulting in a considerable deterioration in the bank's asset quality; (2) there is a significant deterioration in capitalization; or (3) we assess that government support for BIDV has weakened.

LIEN VIET - WHAT COULD CHANGE THE RATING UP

Lien Viet's long-term ratings could be upgraded if Vietnam's sovereign rating is upgraded.

The bank's BCA and long-term ratings could be upgraded if its adjusted problem loan ratio declines to below 4% and its TCE ratio exceeds 10%.

Loan diversification away from real estate and construction loans would also be positive for the bank's BCA.

LIEN VIET - WHAT COULD CHANGE THE RATING DOWN

Lien Viet's long-term ratings could be downgraded if the bank's adjusted problem loan ratio rises above 7% of its gross loans or if its return on tangible assets drops below 0.7%.

The ratings are also sensitive to a significant weakening in the bank's funding or liquidity profile.

MILITARY BANK - WHAT COULD CHANGE THE RATING UP

Moody's will consider upgrading Military Bank's long-term ratings if (1) Vietnam's sovereign rating is upgraded, and (2) the bank posts improved standalone credit metrics that lead to a higher BCA.

Moody's could upgrade Military Bank's BCA if the macroeconomic and operating conditions for banks in Vietnam improve, leading to a higher Macro Profile for the country.

MILITARY BANK - WHAT COULD CHANGE THE RATING DOWN

Moody's could downgrade Military Bank's BCA and ratings if (1) the bank demonstrates a material deterioration in its capital adequacy, or (2) the operating environment deteriorates significantly, against the backdrop of a loosening in the bank's underwriting practices, thereby exposing it to asset-quality risks.

OCB - WHAT COULD CHANGE THE RATING UP

Moody's will consider upgrading the BCA if the bank's adjusted problem loan ratio falls below 4% and its TCE ratio exceeds 10%. Loan diversification away from real estate and construction loans, which Moody's considers as high risk in Vietnam, would also be positive for the BCA. In addition, an improvement in Vietnam's Weak Macro Profile would be BCA positive.

The B2 long-term ratings could be upgraded if both the following conditions are met: the bank's BCA is upgraded and Vietnam's sovereign rating is upgraded.

OCB - WHAT COULD CHANGE THE RATING DOWN

OCB's long-term ratings could be downgraded if its adjusted problem loan ratio rises above 10% of gross loans, or if its TCE ratio drops significantly below 7%. The ratings are also sensitive to a significant weakening in the bank's liquidity.

SHB - WHAT COULD CHANGE THE RATING UP

Moody's will consider raising SHB's BCA if its financial results demonstrate sustained improvement in asset quality and loss-absorbing buffers, including loan-loss reserves and capital buffers. A reform program that drives sustainable recapitalization, greater transparency and more effective risk management could also have positive rating implications for SHB.

Moreover, Moody's could upgrade the BCA if the macroeconomic and operating conditions for banks in Vietnam improve, leading to a higher Macro Profile for the country.

SHB - WHAT COULD CHANGE THE RATING DOWN

The bank's BCA could be downgraded as a result of a material deterioration in its asset quality and capital adequacy levels.

The long-term ratings could be downgraded if there are signs that necessary government support may not be forthcoming to restore economic solvency.

SACOMBANK - WHAT COULD CHANGE THE RATING UP

The ratings could be upgraded if the bank materially improves its solvency profile, by successfully repossessing and disposing of collateral, including writing off large parts of its problem assets. Sustainable improvements in the bank's liquidity profile will also be positive for the rating. Furthermore, a substantial core capital increase will be positive for the ratings.

However, Moody's see a low probability of the bank being recapitalized.

SACOMBANK - WHAT COULD CHANGE THE RATING DOWN

The ratings could be downgraded if the bank achieves only limited success in cleaning its balance sheet through collateral disposals in the next 12-18 months, or if its liquidity profile deteriorates below its currently weak level.

TPBANK - WHAT COULD CHANGE THE RATING UP

Moody's will consider upgrading the BCA if both conditions are met: the adjusted problem loans ratio decreases to below 4%, and TCE ratio exceeds 10%. A material reduction in the market funds ratio will also be positive for the BCA.

The B2 long-term ratings could be upgraded if both conditions are met: BCA is upgraded and Vietnam's government ratings is upgraded.

TPBANK - WHAT COULD CHANGE THE RATING DOWN

The ratings could be downgraded if the problem loans ratio -- as adjusted by Moody's -- increases in excess of 10% of gross loans, or if the TCE ratio drops significantly. The ratings are also sensitive to a significant weakening in the liquidity profile.

The rating could be downgraded if the government rating is lowered, or if the Macro Profile on Vietnam is revised downwards.

VIB - WHAT COULD CHANGE THE RATING UP

Significant improvements in asset quality, coupled with a stable TCE ratio, would be positive for the BCA and credit ratings. Credit ratings could also be upgraded if the sovereign rating is upgraded.

VIB - WHAT COULD CHANGE THE RATING DOWN

The ratings could be downgraded if the bank's asset quality deteriorates to such an extent that potential credit losses almost fully deplete its loss-absorbing buffers. A significant deterioration in capital and liquidity metrics will also be negative for the rating.

VIETINBANK - WHAT COULD CHANGE THE RATING UP

Material improvements in asset quality and the TCE ratio will be positive for the bank's BCA. The long-term ratings of VietinBank could be upgraded if the sovereign rating is upgraded.

VIETINBANK - WHAT COULD CHANGE THE RATING DOWN

The BCA of the bank could be downgraded if there is a material deterioration in its financial metrics, such as a weakening of its asset quality or TCE ratio. The bank's long-term ratings will come under downward pressure if there is a multi-notch downgrade of the BCA, or if the assumptions for government support are lowered.

MSB - WHAT COULD CHANGE THE RATING UP

A material reduction in problem assets, including the bank's Vietnam Asset Management Company balance, could lead to upward rating pressure. Improved profitability will also be positive for the rating.

MSB - WHAT COULD CHANGE THE RATING DOWN

The rating could be downgraded or the outlook revised to stable or negative if there is a further deterioration in asset quality and a material depletion of the bank's capital buffers in the medium term.

VP BANK - WHAT COULD CHANGE THE RATING UP

The long-term ratings could be upgraded if Vietnam's sovereign rating is upgraded.

Moody's will also consider raising VP Bank's BCA and long-term ratings if its financial results demonstrate sustained improvements in asset quality and loss-absorbing buffers, including loan-loss reserves and capital buffers.

Moreover, Moody's could upgrade the BCA of the bank if the macroeconomic and operating conditions for banks in Vietnam improve, leading to a higher Macro Profile for the country.

VP BANK - WHAT COULD CHANGE THE RATING DOWN

VP Bank's long-term ratings could be downgraded if the bank pursues an overly aggressive expansion strategy that leads to a loosening of underwriting practices, which then pose asset-quality risks, or a material decline in capitalization.

TECHCOMBANK - WHAT COULD CHANGE THE RATING UP

Moody's will consider upgrading the bank's ratings if both conditions are met: (1) the sovereign rating of Vietnam is upgraded, and (2) the bank posts improved stand-alone credit metrics that lead to a higher BCA. Moreover, the BCA of the bank could be upgraded if the macroeconomic and operating conditions for banks in Vietnam improve, leading to a higher Macro Profile.

TECHCOMBANK - WHAT COULD CHANGE THE RATING DOWN

The BCA and credit ratings could be downgraded in case of a material deterioration in the bank's solvency and/or liquidity metrics.

The principal methodology used in these ratings was Banks published in June 2018. Please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.

LIST OF ASSIGNED RATINGS

An Binh Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Asia Commercial Bank

Local and foreign currency long-term Counterparty Risk ratings of Ba3 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Ho Chi Minh City Development Joint Stock Commercial Bank

Local and foreign currency long-term Counterparty Risk ratings of B2 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

JSC Bank for Foreign Trade of Vietnam

Local and foreign currency long-term Counterparty Risk ratings of Ba3 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Joint Stock Commercial Bank for Investment and Development of Vietnam

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Lien Viet Post Joint Stock Commercial Bank

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Military Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of Ba3 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Orient Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B2 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Saigon - Hanoi Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B2 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Saigon Thuong Tin Commercial Joint-Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B3 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Tien Phong Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B2 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Vietnam International Bank

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Vietnam Joint-Stock Commercial Bank for Industry and Trade

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Vietnam Maritime Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of B2 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Vietnam Prosperity Joint Stock Commercial Bank

Local and foreign currency long-term Counterparty Risk ratings of B1 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

Vietnam Technological and Commercial Joint Stock Bank

Local and foreign currency long-term Counterparty Risk ratings of Ba3 is assigned

Local and foreign currency short-term Counterparty Risk ratings of Not Prime is assigned

An Binh Commercial Joint Stock Bank (ABB), headquartered in Ho Chi Minh City, reported total assets of VND74,124 billion ($3.25 billion) as of 31 March 2018.

Asia Commercial Bank (ACB), headquartered in Ho Chi Minh City, reported total assets of VND299,855 billion ($13.16 billion) as of 31 March 2018.

Ho Chi Minh City Development Joint Stock Commercial Bank (HDBank), headquartered in Ho Chi Minh City, reported total assets of VND190,374 billion ($8.35 billion) as of 31 March 2018.

JSC Bank for Foreign Trade of Vietnam (Vietcombank), headquartered in Hanoi, reported total assets of VND1,003,906 billion ($44.06 billion) as of 31 March 2018.

Joint Stock Commercial Bank for Investment and Development of Vietnam (BIDV), headquartered in Hanoi, reported total assets of VND1,226,943 billion ($53.85 billion) as of 31 March 2018.

Lien Viet Post Joint Stock Commercial Bank (Lien Viet), headquartered in Hanoi, reported total assets of VND169,797 billion ($7.45 billion) as of 31 March 2018.

Military Commercial Joint Stock Bank (Military Bank), headquartered in Hanoi, reported total assets of VND316,345 billion ($13.88 billion) as of 31 March 2018.

Orient Commercial Joint Stock Bank (OCB), headquartered in Ho Chi Minh City, reported total assets of VND84,300 billion ($3.72 billion) as of 31 December 2017.

Saigon - Hanoi Commercial Joint Stock Bank (SHB), headquartered in Hanoi, reported total assets of VND 286,905 billion ($12.59 billion) as of 31 March 2018.

Saigon Thuong Tin Commercial Joint-Stock Bank (Sacombank), headquartered in Ho Chi Minh City, reported total assets of VND381,252 billion ($16.73 billion) as of 31 March 2018.

Tien Phong Commercial Joint Stock Bank (TPBank), headquartered in Hanoi, reported total assets of VND 121,214 billion ($5.32 billion) as of 31 March 2018.

Vietnam International Bank (VIB), headquartered in Hanoi, reported total assets of VND136,026 billion ($5.97 billion) as of 31 March 2018.

Vietnam Joint-Stock Commercial Bank for Industry and Trade (VietinBank), headquartered in Hanoi, reported total assets of VND1,114,095 billion ($48.89 billion) as of 31 March 2018.

Vietnam Maritime Commercial Joint Stock Bank (MSB), headquartered in Hanoi, reported total assets of VND116,109 billion ($5.10 billion) as of 31 March 2018.

Vietnam Prosperity Joint Stock Commercial Bank (VP Bank), headquartered in Hanoi, reported total assets of VND284,388 billion ($12.48 billion) as of 31 March 2018.

Vietnam Technological and Commercial Joint Stock Bank (Techcombank), headquartered in Hanoi, reported total assets of VND273,153 billion ($11.99 billion) as of 31 March 2018.

REGULATORY DISCLOSURES

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.

Rebaca Tan
Analyst
Financial Institutions Group
Moody's Investors Service Singapore Pte. Ltd.
50 Raffles Place #23-06
Singapore Land Tower
Singapore 48623
Singapore
JOURNALISTS: 852 3758 1350
Client Service: 852 3551 3077

Graeme Knowd
MD - Banking
Financial Institutions Group
JOURNALISTS: 81 3 5408 4110
Client Service: 81 3 5408 4100

Releasing Office:
Moody's Investors Service Singapore Pte. Ltd.
50 Raffles Place #23-06
Singapore Land Tower
Singapore 48623
Singapore
JOURNALISTS: 852 3758 1350
Client Service: 852 3551 3077

No Related Data.
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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.

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