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Rating Action:

Moody's assigns Counterparty Risk Ratings to 18 Italian banks

22 Jun 2018

Ratings are assigned following 6 June 2018 update to Moody's Banks rating methodology

London, 22 June 2018 -- Moody's Investors Service today assigned Counterparty Risk Ratings (CRRs) to the following rated 18 banking groups: UniCredit S.p.A. and its branches in New York and London, Intesa Sanpaolo S.p.A., its branches in New York, London, and Hong Kong, and its subsidiary Banca IMI S.p.A., Banco BPM S.p.A., Banca Monte dei Paschi di Siena S.p.A., its London branch, and its subsidiary MPS Capital Services S.p.A., Unione di Banche Italiane S.p.A., Banca Nazionale del Lavoro S.p.A., Mediobanca S.p.A., BPER Banca S.p.A., Credit Agricole Cariparma S.p.A., Credito Emiliano S.p.A., Banca Carige S.p.A., Credito Valtellinese S.p.A., Banca Sella Holding S.p.A., Unipol Banca S.p.A., Banca del Mezzogiorno -- MCC S.p.A., Mediocredito Trentino-Alto Adige S.p.A.

Moody's Counterparty Risk Ratings (CRRs) 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

In assigning CRRs to the Italian banks subject to this rating action, Moody's starts with the banks' adjusted Baseline Credit Assessments (BCAs) and uses the agency's existing advanced Loss Given Failure (LGF) analysis that takes into account the level of subordination to CRR liabilities in the bank's balance sheet, and assumes a nominal volume of such liabilities.

The CRRs on these Italian banks do not include any further uplift resulting from Moody's expectations for government support: a moderate probability for UniCredit, Intesa Sanpaolo, Banca IMI and Banca del Mezzogiorno -- MCC; low for all the others.

- For 15 banks, the CRRs are three notches above their respective adjusted BCAs, which is the maximum under Moody's advanced LGF analysis: UniCredit, Intesa Sanpaolo, Banca IMI, Banco BPM, Banca Monte dei Paschi di Siena, MPS Capital Services, Unione di Banche Italiane, Mediobanca, BPER Banca, Banca Carige, Credito Valtellinese, Banca Sella Holding, Unipol Banca, Banca del Mezzogiorno -- MCC, and Mediocredito Trentino-Alto Adige.

Although some of these banks are likely to have more than a nominal volume of CRR liabilities at failure, this has no impact on the CRRs because the significant level of subordination below the CRR liabilities at each of the banks already provides the maximum amount of uplift under Moody's rating methodology.

- For three banks, the CRRs are two notches above their respective adjusted BCAs: Banca Nazionale del Lavoro, Credit Agricole Cariparma, Credito Emiliano.

In all cases, the CRRs assigned are equal to or higher than the rated senior debt and deposit ratings, where applicable . This reflects Moody's view that secured counterparties to banks typically benefit from greater protections under insolvency laws and bank resolution regimes than do senior unsecured creditors, and that this benefit is likely to extend to the unsecured portion of such secured transactions in most bank resolution regimes. Moody's believes that in many cases regulators will use their discretion to allow a bank in resolution to continue to honour its CRR liabilities or to transfer those liabilities to another party who will honour them, in part because of the greater complexity of bailing in obligations that fluctuate with market prices, and also because the regulator will typically seek to preserve much of the bank's operations as a going concern in order to maximize the value of the bank in resolution, stabilize the bank quickly, and avoid contagion within the banking system. CRR liabilities at these banking groups therefore benefit from the subordination provided by more junior liabilities, with the extent of the uplift of the CRR from the adjusted BCA depending on the amount of subordination.

For 13 banks, the CRR is in line with the banks' respective Counterparty Risk Assessment (CRA): UniCredit, Banco BPM, Banca Monte dei Paschi di Siena, MPS Capital Services, Unione di Banche Italiane, BPER Banca, Credito Emiliano, Banca Carige, Credito Valtellinese, Banca Sella Holding, Unipol Banca, Banca del Mezzogiorno -- MCC, Mediocredito Trentino-Alto Adige.

For UniCredit the Baa1 long-term CRR is in line with the Baa1(cr) long-term CRA; however, the long-term CRA is on review for downgrade, whilst the CRR is not, reflecting different constraints. While CRAs, as a default measure, are typically constrained at one notch above the sovereign debt rating (Italy, Baa2 on review for downgrade), CRRs as an expected loss measure are typically constrained at two notches above the sovereign debt rating, given the potential for greater recoveries in default.

For the other five banks, the CRR is one notch higher than their respective CRAs: Intesa Sanpaolo, Banca IMI, Banca Nazionale del Lavoro, Mediobanca, Credit Agricole Cariparma. Their long-term CRRs are A3 on review for downgrade, one notch above the long-term CRAs of Baa1(cr) on review for downgrade.

OUTLOOK

CRRs do not carry outlooks. The A3 long-term CRRs of five banks (Intesa Sanpaolo, Banca IMI, Banca Nazionale del Lavoro, Mediobanca, Credit Agricole Cariparma) are on review for downgrade reflecting the review for downgrade on Italy's Baa2 sovereign debt rating; CRRs are typically constrained at two notches above the sovereign debt rating.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE

The CRRs could be upgraded following an upgrade of their respective BCAs; for banks whose CRR benefits from less than three notches of uplift from Moody's advanced LGF approach, higher subordination could also lead to an upgrade of the CRR. However potential upgrades could be constrained by the two-notch difference between the bank's CRR and Italy's sovereign debt rating.

Conversely, the CRRs could be downgraded following a downgrade of their respective BCA, or by a reduction in the stock of bail-in-able debt and deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- UniCredit S.p.A.

The upgrade of UniCredit's long-term CRR could be triggered by an upgrade of the bank's ba1 standalone baseline credit assessment (BCA). UniCredit's ba1 standalone BCA could be upgraded if the rating agency judged that, based on further progress in the bank's restructuring, the bank will meet its 2019 targets in terms of problem loans reduction, capitalisation, and profitability. UniCredit's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of UniCredit could be downgraded following a downgrade of the bank's BCA, which is unlikely given the bank's positive outlook. Furthermore, UniCredit's CRR could be downgraded following a material reduction in the bank's stock of bail-in-able debt and junior deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Intesa Sanpaolo S.p.A.

An upgrade of Intesa Sanpaolo's long-term CRR is unlikely given the current review for downgrade.

The CRR of Intesa Sanpaolo could be downgraded following a downgrade of Italy's sovereign debt rating, a downgrade of the bank's BCA, or a material reduction in the bank's stock of bail-in-able debt and junior deposits. Intesa Sanpaolo's BCA of baa3 could be downgraded following a material deterioration of Italy's operating environment, an increase in the stock of problem loans, or a material reduction in profit or capital.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca IMI S.p.A.

An upgrade of Banca IMI's long-term CRR is unlikely given the current review for downgrade.

The CRR of Banca IMI could be downgraded following a downgrade of Italy's sovereign debt rating, a downgrade of the baa3 BCA of Banca IMI's parent Intesa Sanpaolo, or a material reduction in the bank's stock of bail-in-able debt and junior deposits of Intesa Sanpaolo.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banco BPM S.p.A.

The CRR of Banco BPM could be upgraded following an upgrade of the bank's b1 BCA. The standalone BCA of Banco BPM could be upgraded if the group were to make material progress in meeting the targets of its strategic plan, which assumes a substantial reduction in the stock of problem loans while preserving profit generation capacity and capital.

A downgrade of the bank's BCA could prompt a downgrade of its CRR. This could be triggered by the group's failure to meet its targeted improvement in key financial fundamentals or a deterioration from current levels. Any deterioration in the bank's liquidity profile could also exert negative pressure on the BCA.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca Monte dei Paschi di Siena S.p.A.

The upgrade of Banca Monte dei Paschi di Siena's long-term CRR could be triggered by an upgrade of the bank's caa1 baseline credit assessment (BCA). Banca Monte dei Paschi di Siena's BCA could be upgraded following tangible and sustainable progress towards MPS' targets under its business plan (2021), in particular: (i) a return on assets above 0.4%; (ii) a problem loan ratio below 15% of loans; and (iii) increased deposit funding or demonstrated access to the senior and subordinated debt markets, without the benefit of a government guarantee. Banca Monte dei Paschi di Siena's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of Banca Monte dei Paschi di Siena could be downgraded following a downgrade of the bank's BCA or a material reduction in the bank's stock of bail-in-able debt and junior deposits. Moody's could downgrade the BCA if (i) the bank fails to return to sustainable profit generation; (ii) the CET1 ratio falls below 12%; (iii) problem loans increase materially ; or (iv) the bank is not able to increase deposits and remains reliant on government guaranteed funding.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Unione di Banche Italiane S.p.A.

The CRR of Unione di Banche Italiane could be upgraded following an upgrade of the bank's ba2 BCA. An upgrade of Unione di Banche Italiane's BCA could be driven by: (i) a substantial increase in capitalization; (ii) a material improvement in the bank's asset risk profile; and/or (iii) a sustainable recovery in the bank's recurring earnings.

A downgrade of the bank's BCA could prompt a downgrade of its CRR. A downgrade of the bank's BCA could result from: (i) a reversal in current asset risk trends with an increase in the stock of problem loans; (ii) a weakening of Unione di Banche Italiane's risk-absorption capacity as a result of deteriorating profitability or capital levels; and/or (iii) a significant deterioration of the bank's liquidity profile.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca Nazionale del Lavoro S.p.A.

An upgrade of Banca Nazionale del Lavoro's CRR is unlikely given the current review for downgrade.

Conversely, Banca Nazionale del Lavoro's CRR could be downgraded if (i) Italy's sovereign debt rating were downgraded; (ii) Banca Nazionale del Lavoro's baa2 adjusted BCA were downgraded following a material deterioration of capital and asset risk or Moody's reduced the probability of support from BNP Paribas (Aa3 stable, baa1); or (iii) following a material reduction in the stock of bail-in-able debt and junior deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Mediobanca S.p.A.

An upgrade of Mediobanca's long-term CRR is unlikely given the current review for downgrade. Moreover Mediobanca's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of Mediobanca could be downgraded following a downgrade of Italy's sovereign debt rating, a downgrade of the bank's BCA, or a material reduction in the bank's stock of bail-in-able debt and junior deposits. Mediobanca's BCA of baa3 could be downgraded if reliance on capital market activities were to increase; if capital ratios were to decrease materially; or if its dependence on short-term wholesale funding were to rise.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- BPER Banca S.p.A.

The upgrade of BPER Banca's long-term CRR could be triggered by an upgrade of the bank's ba3 baseline credit assessment (BCA). BPER Banca's BCA could be upgraded if the bank were to (i) significantly reduce problem loans while maintaining strong levels of capitalisation; and (ii) show a sustained increase in profitability. BPER Banca's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of BPER Banca could be downgraded following a downgrade of the bank's BCA or a material reduction in the bank's stock of bail-in-able debt and junior deposits. The BCA could be downgraded if: (i) problem loans were to fail to decline materially; (ii) capital were to fall further than expected; or (iii) there were a structural decline in profitability.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Credit Agricole Cariparma S.p.A.

An upgrade of Credit Agricole Cariparma's long-term CRR is unlikely given the current review for downgrade.

The CRR of Credit Agricole Cariparma could be downgraded following a downgrade of Italy's sovereign debt rating, a downgrade of the bank's parent Credit Agricole S.A. (A1 stable, baa3), evidence of reduced support from Credit Agricole, or a substantial reduction in Credit Agricole Cariparma's stock of bail-in-able debt.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Credito Emiliano S.p.A.

An upgrade of Credito Emiliano's long-term CRR could be triggered by an upgrade of the bank's baa3 baseline credit assessment (BCA). Credito Emiliano's BCA could be upgraded following an improvement in its operating environment.

The CRR of Credito Emiliano could be downgraded following a downgrade of the bank's BCA or a material reduction in the bank's stock of bail-in-able debt and junior deposits. The BCA could be downgraded following a material increase in the stock of problem loans, a reduction of capital or profitability, or a deterioration of Italy's operating environment.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca Carige S.p.A.

The upgrade of Banca Carige's long-term CRR could be triggered by an upgrade of the bank's caa1 baseline credit assessment (BCA). Moody's could upgrade Banca Carige's BCA if the bank makes significant progress in its restructuring plan, in particular a material improvement in profitability and further significant de-risking, without compromising its target capital levels. Banca Carige's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of Banca Carige could be downgraded following a downgrade of the bank's BCA or a material reduction in the bank's stock of bail-in-able debt and junior deposits. Moody's could downgrade the BCA if further losses were to reduce Banca Carige's capital headroom over its prudential requirement.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Credito Valtellinese S.p.A.

Credito Valtellinese's CRR could be upgraded if its adjusted BCA of b2 were upgraded, following significant progress towards its business plan targets, in particular profitability.

Conversely, Credito Valtellinese's CRR could be downgraded (i) if the bank failed to return to adequate profitability, or were unable to execute the planned sale of loans; or (ii) following a material reduction in the stock of bail-in-able debt and junior deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca Sella Holding S.p.A.

Banca Sella's CRR could be upgraded if its adjusted BCA of ba2 were upgraded, following further improvements in capital, a larger than-expected reduction in the stock of problem loans and an improvement in profitability.

Conversely, Banca Sella's CRR could be downgraded (i) if its adjusted BCA were downgraded following a material increase in the stock of problem loans or net losses reducing capital; or (ii) following a material reduction in the stock of bail-in-able debt and junior deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Unipol Banca S.p.A.

Unipol Banca's CRR could be upgraded if its adjusted BCA of b1 were to be upgraded, following achievement of a sustained improvement in profitability and resolution of the current strategic uncertainty.

Conversely, Moody's could downgrade Unipol Banca's CRR if (i) continuing losses eroded the CET1 ratio below 9%; (ii) the parent Unipol Gruppo S.p.A. were to be downgraded; (iii) Moody's were to consider that the likelihood of support from the parent had fallen further; or (iv) following a material reduction in the stock of bail-in-able debt and junior deposits.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Banca del Mezzogiorno -- MCC S.p.A.

The CRR of Banca del Mezzogiorno - MCC could be upgraded following an upgrade of the bank's ba3 BCA, or by an upgrade of Italy's sovereign debt rating, which is however unlikely given the current review for downgrade on the latter. Banca del Mezzogiorno - MCC's BCA could be upgraded following a track record of low cost of risk and greater diversification of funding sources.

Banca del Mezzogiorno - MCC's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

Banca del Mezzogiorno - MCC's CRR could be downgraded following a downgrade of the bank's BCA, or following a material reduction in the bank's stock of bail-in-able debt and junior deposit. Banca del Mezzogiorno - MCC's BCA could be downgraded following a considerable deterioration in the bank's loan book or a material reduction in capital.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE -- Mediocredito Trentino-Alto Adige S.p.A.

The upgrade of Mediocredito Trentino-Alto Adige's long-term CRR could be triggered by an upgrade of the bank's ba3 baseline credit assessment (BCA). Mediocredito Trentino-Alto Adige's BCA could be upgraded following a material further reduction in problem loans, improved profitability, and a significantly reduced reliance on wholesale funding. Mediocredito Trentino-Alto Adige's CRR already benefits from three notches of uplift from Moody's advanced LGF approach, which is the maximum amount of uplift under the rating agency's rating methodology.

The CRR of Mediocredito Trentino-Alto Adige could be downgraded following a downgrade of the bank's BCA or a material reduction in the bank's stock of bail-in-able debt and junior deposits. The BCA could be downgraded following a deterioration in asset quality or profitability, which could exert pressure on capital.

LIST OF AFFECTED RATINGS

Issuer: Banca Carige S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned B1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: Banca del Mezzogiorno - MCC S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa3

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-3

Issuer: Banca IMI S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Banca Monte dei Paschi di Siena S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned B1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: Banca Monte dei Paschi di Siena, London

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned B1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: Banca Nazionale Del Lavoro S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Banca Sella Holding S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa2

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Banco BPM S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Ba1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: BPER Banca S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa3

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-3

Issuer: Credit Agricole Cariparma S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Credito Emiliano S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Credito Valtellinese S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Ba2

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: Intesa Sanpaolo S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Intesa Sanpaolo S.p.A., Hong Kong Branch

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Intesa Sanpaolo S.p.A., London Branch

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Intesa Sanpaolo S.p.A., New York Branch

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Mediobanca S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned A3; placed on review for downgrade

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Mediocredito Trentino-Alto Adige S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa3

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-3

Issuer: MPS Capital Services S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned B1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

Issuer: UniCredit S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: UniCredit S.p.A., London Branch

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: UniCredit S.p.A., New York Branch

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Unione di Banche Italiane S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Baa2

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned P-2

Issuer: Unipol Banca S.p.A.

..Assignments:

....Long-term Counterparty Risk Rating (Local and Foreign Currency), assigned Ba1

....Short-term Counterparty Risk Rating (Local and Foreign Currency), assigned NP

PRINCPAL METHODOLOGY

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.

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.

The relevant office for each credit rating is identified in "Debt/deal box" on the Ratings tab in the Debt/Deal List section of each issuer/entity page of the website.

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.

Edoardo Calandro
Vice President - Senior Analyst
Financial Institutions Group
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

Nicholas Hill
MD - Banking
Financial Institutions Group
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

Releasing Office:
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
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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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