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Rating Action:

Moody's changes outlook on nine Mongolian banks to negative following sovereign action; affirms all ratings

11 May 2020

Hong Kong, May 11, 2020 -- Moody's Investors Service has today changed the outlook to negative from stable and affirmed all ratings and assessments of the nine banks it rates in Mongolia (B3 negative).

The rating action follows the outlook change to negative from stable on the Mongolian government's B3 issuer rating on 8 May 2020. For further information on the sovereign rating action, please refer to Moody's press release: Moody's changes Mongolia's outlook to negative from stable; affirms B3 rating (https://www.moodys.com/research/Moodys-changes-Mongolias-outlook-to-negative-from-stable-affirms-B3--PR_423017).

The nine affected banks are: (1) Bogd Bank LLC, (2) Capitron Bank LLC, (3) Development Bank of Mongolia LLC, (4) Golomt Bank LLC, (5) Khan Bank LLC, (6) State Bank LLC, (7) Trade and Development Bank of Mongolia LLC, (8) Transport and Development Bank LLC, and (9) XacBank LLC.

A full list of the affected ratings can be found at the bottom of this press release.

RATINGS RATIONALE

The change in outlook to negative for the nine Mongolian banks reflects Moody's view that there is high correlation between the creditworthiness of the Mongolian banking system and that of the sovereign, given (1) the concentration of their operations in Mongolia; and (2) their significant direct and indirect exposures to domestic sovereign debt relative to their capital bases.

In addition, Moody's expects that the operating environment for Mongolian banks will deteriorate in the next 12-18 months due to disruptions from the coronavirus outbreak, which may lead to a weakening in the banks' asset quality and profitability.

The rapid and widening spread of the coronavirus outbreak, deteriorating global economic outlook, volatile oil prices, and asset price declines are creating a severe and extensive credit shock across many sectors, regions and markets. The Mongolian banking system has been one of the sectors affected by the shock, particularly given the role that commodity exports play in Mongolia's economy. Moody's regards the coronavirus outbreak as a social risk under its ESG framework, given the substantial implications for public health and safety.

Notwithstanding the negative outlook, Moody's has affirmed the ratings of the banks to reflect their current financial strength, underpinned by favorable funding, liquidity and moderate capital buffers. Rationales for the individual banks are provided later in this press release.

ISSUER-SPECIFIC RATING DRIVERS

Bogd Bank LLC

The affirmation of Bogd Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 Baseline Credit Assessment (BCA).

Bogd Bank's b3 BCA reflects its strong equity capital and highly liquid balance sheet. At the same time, its BCA is constrained by its modest funding profile with the highest level of market funds to tangible banking assets among rated Mongolian peers, as reflected by a tangible common equity to risk weighted assets of 31.2% at the end of 2019.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Bogd Bank's credit metrics.

Capitron Bank LLC

The affirmation of Capitron Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

Capitron Bank's b3 BCA balances the bank's rising asset risks with Moody's expectation of continued shareholder support that will help the bank maintain a moderate capital position and liquid balance sheet. Capitron Bank's asset risk has risen given its credit concentration in the mining and construction sectors that Moody's view as high risk sectors. The bank's problem loans ratio deteriorated to 17.5% at the end of 2019 from 10.9% at the end of 2018. Its capitalization also fell to 12.2% at the end of 2019 from 16.1% at the end of 2018 driven by high loan growth.

In a move that offset the bank's deteriorating asset quality and capitalization, the shareholders of Capitron Bank injected equity capital into the bank in 2019, and helped increase its share capital by MNT5 billion to MNT80 billion at the end of 2019. Moody's expects additional capital injections by shareholders, given the tightening regulatory environment in Mongolia that requires banks' share capital to reach MNT100 billion by the end of 2021.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Capitron Bank's credit metrics.

Development Bank of Mongolia LLC

The affirmation of Development Bank of Mongolia's B3 long-term issuer rating reflects the affirmation of the bank's b3 BCA.

Development Bank of Mongolia's b3 BCA balances the bank's rising asset risk with a very high level of capitalization. The bank's problem loans ratio deteriorated to 18.9% at the end of 2019 from 10.3% at the end of 2018, reflecting the high concentration risk associated with the bank's policy role to provide funds to strategically important sectors and large projects. However, Development Bank of Mongolia's capitalization is very strong, as reflected by a tangible common equity to risk weighted assets ratio of 30.0% at the end of 2019.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Development Bank of Mongolia's credit metrics.

Golomt Bank LLC

The affirmation of Golomt Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

The affirmation of Golomt Bank's b3 BCA reflects the bank's strong funding and liquidity profile, which is helping offset its high asset risk and weak profitability. The bank's reliance on market funding is low relative to its domestic banking peers. However, the bank's problem loans ratio was high compared to domestic bank peers at 15.0% at the end of 2019, reflecting the high asset risks stemming from its exposure to the corporate sector.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Golomt Bank's credit metrics.

Khan Bank LLC

The affirmation of Khan Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

Khan Bank's b3 BCA reflects the bank's strong profitability, good funding and liquidity, and moderate capitalization given its robust franchise as the largest bank in Mongolia. Khan Bank's granular loan book, with high retail borrower composition, supports the bank's relatively stronger asset quality compared to domestic bank peers.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Khan Bank's credit metrics.

State Bank LLC

The affirmation of State Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

State Bank's b3 BCA reflects the bank's strong retail franchise, which is allowing the bank to maintain stable funding and liquidity. In addition, its loan book is relatively granular with high retail borrower composition. At the same time, the bank's capitalization ratio improved to 8.9% at the end of 2019 from 7.8% at the end of 2018, driven by additional capital injections from the government.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken State Bank's credit metrics.

Trade and Development Bank of Mongolia LLC

The affirmation of Trade and Development Bank of Mongolia's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

Trade and Development Bank of Mongolia's b3 BCA reflects Moody's view that the bank will maintain sufficient liquidity to repay a maturing $500 million bond on 19 May 2020. The bank's b3 BCA also reflects its strong franchise as the second largest bank in Mongolia, allowing the bank to maintain stable funding and liquidity despite its very high level of problem loans and modest capitalization.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken the credit metrics of Trade Development Bank of Mongolia.

Transport and Development Bank LLC

The affirmation of Transport and Development Bank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

The affirmation of Transportation and Development Bank's b3 BCA reflects its relatively higher level of capitalization with a tangible common equity to risk weighted assets ratio of 24.7% at the end of 2019, which helps offset the challenges that the bank faces as a small bank in accessing sticky deposit funding and managing liquidity.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken Transport and Development Bank's credit metrics.

XacBank LLC

The affirmation of XacBank's B3 long-term deposit ratings reflects the affirmation of the bank's b3 BCA.

The affirmation of XacBank's b3 BCA reflects its balanced asset portfolio of retail and corporate clients and its low problem loans ratio, which was 4.8% at the end of 2019, the lowest among domestic banking peers. The bank's b3 BCA also reflects its modest capitalization and weak profitability. The bank has a highly liquid balance sheet with a liquid banking asset to tangible banking assets ratio of 41.0% at the end of 2019.

The negative outlook reflects Moody's expectation for a significant economic slowdown in Mongolia, as expressed by the negative outlook on Mongolia's sovereign rating, and the resulting deterioration in the operating environment of Mongolian banks, which may weaken XacBank's credit metrics.

Moody's has not incorporated affiliate support for the nine Mongolian banks, and therefore the adjusted BCAs are in-line with the banks' BCAs of b3.

No government support uplift is reflected in the nine Mongolian banks' ratings because the banks' BCAs are at the same level as the Mongolian government's issuer rating of B3. Nonetheless, Moody's assumes government-backed level of support for Development Bank of Mongolia given its important policy role in supporting strategically important sectors. Moody's assumes a high level of government support for systemically important banks, including Khan Bank, Trade and Development Bank of Mongolia, Golomt Bank, XacBank and State Bank. Moody's assumes a low level of government support for smaller banks, including Bogd Bank, Capitron Bank and Transport and Development Bank.

For all affected Mongolian banks' long-term CR Assessment of B2(cr) and long-term CRRs of B2 take into consideration the b3 Adjusted BCA and Moody's Basic LGF analysis, which positions the Preliminary Rating Assessment of the CR Assessment and CRRs one notch above the bank's Adjusted BCA, prior to the incorporation of government support.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

WHAT COULD CHANGE THE RATING UP

Given the negative outlook, any upgrade of the banks' ratings is unlikely in the near future. The outlook on the long-term deposit ratings could be moved back to stable if the sovereign's outlook moves back to stable and the risks in the operating environment remain broadly stable.

WHAT COULD CHANGE THE RATING DOWN

Moody's could downgrade the ratings of the nine banks if their BCAs are downgraded, and/or the sovereign rating is downgraded. The banks' BCAs could be downgraded if their problem loans rise significantly without a strengthening of capitalization. Material deterioration of the banks' funding and/or liquidity strength could also result in a downgrade of the banks' BCAs.

The principal methodology used in these ratings was Banks Methodology published in November 2019 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1147865. Alternatively, please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.

All entities are headquartered in Ulaanbaatar. The banks reported the following assets as of 31 December 2019:

Bogd Bank LLC: MNT249 billion (USD91 million)

Capitron Bank LLC: MNT1.0 trillion (USD369 million)

Development Bank of Mongolia LLC: MNT4.27 trillion (USD1.56 billion)

Golomt Bank LLC: MNT6.64 trillion (USD2.43 billion)

Khan Bank LLC: MNT10.19 trillion (USD3.72 billion)

State Bank LLC: MNT3.30 trillion (USD1.20 billion)

Trade and Development Bank of Mongolia LLC: MNT7.80 trillion (USD2.85 billion)

Transport and Development Bank LLC: MNT524 billion (USD191 million)

XacBank LLC: MNT3.45 trillion (USD1.26 billion)

LIST OF AFFECTED RATINGS

Issuer: Bogd Bank LLC (Analyst: Sophia Lee)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Outlook changed to negative from stable

Issuer: Capitron Bank LLC (Analyst: Tae Jong Ok)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term issuer ratings of NP affirmed

- Outlook changed to negative from stable

Issuer: Development Bank of Mongolia LLC (Analyst: Tae Jong Ok)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Foreign currency long-term issuer rating of B3 affirmed, outlook changed to negative from stable

- Outlook changed to negative from stable

Issuer: Golomt Bank LLC (Analyst: Tae Jong Ok)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Outlook changed to negative from stable

Issuer: Khan Bank LLC (Analyst: Sophia Lee)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Outlook changed to negative from stable

Issuer: State Bank LLC (Analyst: Tae Jong Ok)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Outlook changed to negative from stable

Issuer: Trade and Development Bank of Mongolia LLC (Analyst: Tae Jong Ok)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term issuer ratings of NP affirmed

- Foreign currency backed senior unsecured rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency senior unsecured MTN rating of (P)B3 affirmed

- Outlook changed to negative from stable

Issuer: Transport and Development Bank LLC (Analyst: Sophia Lee)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term issuer ratings of NP affirmed

- Outlook changed to negative from stable

Issuer: XacBank LLC (Analyst: Sophia Lee)

- Baseline Credit Assessment (BCA) of b3 affirmed

- Adjusted BCA of b3 affirmed

- Long-term Counterparty Risk Assessment of B2(cr) affirmed

- Short-term Counterparty Risk Assessment affirmed at NP(cr)

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

- Local currency and foreign currency short-term Counterparty Risk Ratings of NP affirmed

- Local currency long-term deposit rating of B3 affirmed, outlook changed to negative from stable

- Foreign currency long-term deposit rating of Caa1 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term deposit ratings of NP affirmed

- Local currency and foreign currency long-term issuer ratings of B3 affirmed, outlook changed to negative from stable

- Local currency and foreign currency short-term issuer ratings of NP affirmed

- Foreign currency senior unsecured MTN rating of (P)B3 affirmed

- Foreign currency other short-term rating of (P)NP affirmed

- Outlook changed to negative from stable

REGULATORY DISCLOSURES

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody's Rating Symbols and Definitions can be found at: https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_79004.

For ratings issued on a program, series, category/class of debt or security this announcement provides certain regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series, category/class of debt, security 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 ratings have been disclosed to the rated entity or its designated agent(s) and issued with no amendment resulting from that disclosure.

These ratings are solicited. Please refer to Moody's Policy for Designating and Assigning Unsolicited Credit Ratings available on its website www.moodys.com.

Moody's considers a rated entity or its agent(s) to be participating when it maintains an overall relationship with Moody's. Unless noted in the Regulatory Disclosures as a Non-Participating Entity, the rated entities are participating and the rated entities or their agent(s) generally provide Moody's with information for the purposes of its ratings process. Please refer to www.moodys.com for the Regulatory Disclosures for each credit rating action under the ratings tab on the issuer/entity page and for details of Moody's Policy for Designating Non-Participating Rated Entities.

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

Moody's general principles for assessing environmental, social and governance (ESG) risks in our credit analysis can be found at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1133569.

At least one ESG consideration was material to the credit rating action(s) announced and described above.

The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody's affiliates outside the EU and is endorsed by Moody's Deutschland GmbH, An der Welle 5, Frankfurt am Main 60322, Germany, in accordance with Art.4 paragraph 3 of the Regulation (EC) No 1060/2009 on Credit Rating Agencies. Further information on the EU endorsement status and on the Moody's office that issued the credit rating is available on www.moodys.com.

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.

The first name below is the lead rating analyst for this Credit Rating and the last name below is the person primarily responsible for approving this Credit Rating.

Tae Jong Ok
Asst Vice President - Analyst
Financial Institutions Group
Moody's Investors Service Hong Kong Ltd.
24/F One Pacific Place
88 Queensway
Hong Kong
China (Hong Kong S.A.R.)
JOURNALISTS: 852 3758 1350
Client Service: 852 3551 3077

Stephen Long
MD - Financial Institutions
Financial Institutions Group
JOURNALISTS: 852 3758 1350
Client Service: 852 3551 3077

Releasing Office:
Moody's Investors Service Hong Kong Ltd.
24/F One Pacific Place
88 Queensway
Hong Kong
China (Hong Kong S.A.R.)
JOURNALISTS: 852 3758 1350
Client Service: 852 3551 3077

No Related Data.
© 2021 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 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 $5,000,000. 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 JPY550,000,000.

MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.