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Rating Action:

Moody's assigns Counterparty Risk Ratings to bank subsidiaries and branches of 43 Brazilian banks

22 Jun 2018

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

New York, June 22, 2018 -- Moody's Investors Service ("Moody's") has today assigned Counterparty Risk Ratings (CRRs) to 43 Brazilian banks and foreign branches. In addition, Moody's assigned Counterparty Risk Assessments (CRAs) to Banco Nacional de Desenvolvimento Economico e Social (BNDES) and to Banco Cooperativo Sicredi S.A. (Sicredi). At the same time, the long-term CRA assigned to Banco Mizuho do Brasil S.A. (Mizuho Brazil) was downgraded to Baa2(cr).

Moody's Counterparty Risk Ratings (CRR) are opinions of the ability of entities to honor 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 honored. 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 aforementioned banks are positioned one notch above the banks' Adjusted Baseline Credit Assessment (BCA) to reflect the lower probability of default of CRR liabilities and Moody's expectation of a normal level of loss given default. Moody's does not consider Brazil to have an operational bank resolution regime (non-ORR), therefore, in assigning CRRs, the rating agency employs the same approach for other rated liabilities. The CRRs are at the same level of the banks' CRAs.

In Moody's view, secured counterparties to banks typically benefit from greater protections under insolvency laws and bank resolution regimes than do senior unsecured creditors, and 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 honor its CRR liabilities or to transfer those liabilities to another party who will honor 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.

In the cases of the state-owned banks Caixa Economica Federal (Caixa) and Banco do Nordeste do Brasil S.A. (BNB), the CRAs and CRRs also receive uplift from governmental support.

As a result, of the CRRs assigned to 43 banks and branches, 90% of the local currency CRRs are one notch higher than their respective senior debt and local currency deposit ratings, while remaining four banks' CRRs are at the same level of their respective local currency deposit ratings. Those cases in which the local currency CRR is in line with the corresponding deposit rating are: (1) Caixa and BNB with CRRs of Ba2, because the CRRs for these issuers receive less uplift from government support than their debt and deposit ratings due to their higher starting points ; (2) Mizuho Brazil, with a Baa2 long-term local currency CRR aligned to its adjusted BCA of baa2, because the adjusted BCA is already three notches above Brazil's Ba2 sovereign rating due to parental support, and (3) ING Bank N.V. -- São Paulo Branch, with an A3 CRR, the same level as its deposit rating and Brazil's country ceiling.

In addition, the long-term foreign currency CRRs assigned to eight foreign-owned banks (Banco Cetelem S.A., Banco Citibank S.A., ING Bank N.V. São Paulo Branch, Banco Santander (Brasil) and to its Cayman Branch, Banco Ford S.A., Banco RCI Brasil S.A., Mizuho Brazil and China Construction Bank (Brasil) S.A. and to its Cayman Branch) are constrained by Brazil's foreign currency debt ceiling of Ba1.

BANCO MIZUHO DO BRASIL S.A.

Mizuho Brazil's CRA was downgraded to bring it into line with the bank's adjusted BCA and deposit rating, both of which incorporate a four-notch uplift from the bank's standalone BCA of ba3 because of the very high probability that the bank will receive support from its foreign owner, Mizuho Bank Ltd (A1 stable, baa1). Given that the adjusted BCA and deposit rating are already three notches above Brazil's sovereign rating, Moody's has concluded that the risk of default on the operational obligations represented by the CRA should be aligned with the adjusted BCA in recognition of affiliate support, which allows the CRA to exceed the limit of two notches above the sovereign rating

The following ratings were assigned to banks in Brazil and their respective offshore branches:

Banco Bradesco S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Bradesco S.A., Grand Cayman Branch

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Itau Unibanco S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Itau Unibanco S.A. (Cayman Islands)

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Banco ABC Brasil S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Alfa de Investimento S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco BMG S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba3

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of A3.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-2

Banco BOCOM BBM S.A.

Local currency long-term Counterparty Risk Rating of Baa3

Local currency short-term Counterparty Risk Rating of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco BTG Pactual S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco BTG Pactual S.A., Grand Cayman Branch

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Banco BTG Pactual S.A., Luxembourg Branch

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Banco Cetelem S.A.

Local currency long-term Counterparty Risk Rating of Baa3

Local currency short-term Counterparty Risk Rating of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Citibank S.A.

Local currency long-term Counterparty Risk Rating of Baa3

Local currency short-term Counterparty Risk Rating of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Cooperativo Sicredi S.A.

Long-term Counterparty Risk Assessment of Ba1(cr)

Short-term Counterparty Risk Assessment of Not Prime(cr)

Local currency and foreign currency long-term Counterparty Risk Rating of Ba1

Local currency and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Daycoval S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco do Brasil S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco do Brasil S.A. (Cayman)

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Banco do Estado de Sergipe S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco do Estado do Pará S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco do Estado do Rio Grande do Sul S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba2

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aa1.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco do Nordeste do Brasil S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba2

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aa2.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Fibra S.A.

Local and foreign currency long-term Counterparty Risk Ratings of B2

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Ba2.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-4

Banco Ford S.A.

Local currency long-term Counterparty Risk Rating of Baa3

Local currency short-term Counterparty Risk Rating of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Industrial do Brasil S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Mercantil do Brasil S.A.

Local and foreign currency long-term Counterparty Risk Ratings of B3, on review for downgrade

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of B2.br, on review for downgrade

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-4

Banco Mizuho do Brasil S.A.

Local currency long-term Counterparty Risk Rating of Baa2

Local currency short-term Counterparty Risk Rating of Prime-2

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Modal S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba3

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of A2.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Nac. Desenv. Economico e Social - BNDES

Long-term Counterparty Risk Assessment of Ba1(cr)

Short-term Counterparty Risk Assessment of Not Prime(cr)

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Pan S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba3

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of A2.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Psa Finance Brasil S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco RCI Brasil S.A.

Local currency long-term Counterparty Risk Rating of Baa3

Local currency short-term Counterparty Risk Rating of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Safra S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Safra S.A. (Cayman Branch)

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Banco Santander (Brasil) S.A.

Local currency long-term Counterparty Risk Ratings of Baa3

Local currency short-term Counterparty Risk Ratings of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Santander (Brasil) S.A. - Cayman Branch

Local currency long-term Counterparty Risk Ratings of Baa3

Local currency short-term Counterparty Risk Ratings of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Banco Sofisa S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Votorantim S.A.

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

Banco Votorantim S.A. (Nassau Branch)

Local and foreign currency long-term Counterparty Risk Ratings of Ba1

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Caixa Economica Federal (CAIXA)

Local and foreign currency long-term Counterparty Risk Ratings of Ba2

Local and foreign currency short-term Counterparty Risk Ratings of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aa1.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

China Construction Bank (Brasil) S.A.

Local currency long-term Counterparty Risk Ratings of Baa3

Local currency short-term Counterparty Risk Ratings of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

China Construction Bank (Brasil) S.A., Cayman

Local currency long-term Counterparty Risk Ratings of Baa3

Local currency short-term Counterparty Risk Ratings of Prime-3

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

ICBC do Brasil Banco Multiplo S.A.

Local and foreign currency long-term Counterparty Risk Rating of Ba1

Local and foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

ING Bank N.V. -- São Paulo

Local currency long-term Counterparty Risk Rating of A3

Local currency short-term Counterparty Risk Rating of Prime-2

Foreign currency long-term Counterparty Risk Rating of Ba1

Foreign currency short-term Counterparty Risk Rating of Not Prime

Brazilian local currency long-term national scale Counterparty Risk Rating of Aaa.br

Brazilian local currency short-term national scale Counterparty Risk Rating of BR-1

The following assessment assigned to Banco Mizuho do Brasil S.A. was downgraded:

Long-term Counterparty Risk Assessment to Baa2(cr), from Baa1(cr)

What Could Change the Rating Up/Down

For domestic banks whose BCAs are currently below Brazil's Ba2 sovereign rating, as well as for Banco Cetelem S.A. (Cetelem Brazil), a subsidiary of BNP Paribas (Aa3 stable, baa1) in France , their CRRs could face positive pressure as a result of steady improvement in financial metrics, particularly profitability and asset risk, as well as higher diversification and reducing sector concentration in loan portfolios. For banks whose BCAs are aligned with the sovereign rating, as well as for Caixa and BNB, whose CRRs benefit from government support, the CRRs could face positive pressure if the sovereign is upgraded, except for Mizuho Brazil, Banco Santander (Brasil) S.A., Banco Ford S.A. and Banco Citibank S.A., all of which are foreign-owned and already benefit from affiliate support. Negative pressure on CRRs could result from persistent deterioration in asset quality or a decline in profitability, except for Banco Ford S.A as well as Banco Bocom BBM S.A., Cetelem Brazil, China Construction Bank (Brasil) S.A., and ICBC do Brasil Banco Multiplo S.A., all of whose ratings also benefit from support from their foreign affiliates. For banks whose BCAs are aligned with the sovereign rating, their CRRs would face downward pressure if the sovereign is downgraded, subject to the same exceptions. ING's CRR would face upward or downward pressure if Brazil's country ceiling increases or decreases. The CRRs of Banco Ford S.A. and Banco RCI Brasil S.A would face also upward pressure if their foreign parent's adjusted BCAs are increased, . and Banco RCI Brasil S.A's CRRs would face downward pressure if its parent's adjusted BCAs were lowered.

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.

Moody's National Scale Credit Ratings (NSRs) are intended as relative measures of creditworthiness among debt issues and issuers within a country, enabling market participants to better differentiate relative risks. NSRs differ from Moody's global scale credit ratings in that they are not globally comparable with the full universe of Moody's rated entities, but only with NSRs for other rated debt issues and issuers within the same country. NSRs are designated by a ".nn" country modifier signifying the relevant country, as in ".za" for South Africa. For further information on Moody's approach to national scale credit ratings, please refer to Moody's Credit rating Methodology published in May 2016 entitled "Mapping National Scale Ratings from Global Scale Ratings". While NSRs have no inherent absolute meaning in terms of default risk or expected loss, a historical probability of default consistent with a given NSR can be inferred from the GSR to which it maps back at that particular point in time. For information on the historical default rates associated with different global scale rating categories over different investment horizons, please see https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1113601.

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.

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.

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

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.

Alexandre Albuquerque
Vice President - Senior Analyst
Financial Institutions Group
Moody's America Latina Ltda.
Avenida Nacoes Unidas, 12.551
16th Floor, Room 1601
Sao Paulo, SP 04578-903
Brazil
JOURNALISTS: 800 891 2518
Client Service: 1 212 553 1653

M. Celina Vansetti-Hutchins
MD - Banking
Financial Institutions 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

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.

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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 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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