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Rating Action:

Moody's concludes review for downgrade on 13 banks in Jordan, Lebanon, Pakistan, Ukraine

31 May 2012

Downgrade of standalone assessments in line with Moody's global guidance; deposit and debt ratings affected in most cases

London, 31 May 2012 -- Moody's Investors Service has today lowered the standalone assessments of 13 banks in Jordan, Lebanon, Pakistan and Ukraine. Today's rating actions conclude the review that Moody's initiated on 5 April 2012 in the context of an ongoing global review affecting all banks whose standalone assessments are higher than the rating of the government where they are domiciled. The downward revision of the affected banks' standalone assessments reflects Moody's opinion of the extent to which their creditworthiness is correlated with that of their domestic governments' credit strengths.

The rationale for each affected banks' ratings is provided below in the section entitled List of Rating Actions.

These rating actions stem from Moody's updated assessment of the linkage between the credit profiles of sovereigns and financial institutions domiciled within the country, which is discussed in the rating implementation guidance "How Sovereign Credit Quality May Affect Other Ratings" published on 13 February 2012, and further detailed in the special comment "Banks and Sovereigns: Risk Correlations Constrain Standalone Bank Credit Assessments" published on 30 April 2012.

RATINGS RATIONALE

- STANDALONE ASSESSMENTS

The downward revision of the affected banks' standalone assessments takes into account (i) the degree to which their businesses depend on the domestic macroeconomic and financial environment; (ii) the extent of reliance on market-based funding, which is typically more confidence-sensitive; and (iii) their direct or indirect exposures to domestic sovereign debt relative to their capital cushions. Due to these factors, the standalone ratings of all 13 affected banks were lowered by one to three notches.

The standalone credit assessments of 11 of the 13 banks were lowered to the level of their domestic government debt rating, reflecting Moody's view that their creditworthiness is highly correlated to that of their respective national government. The key drivers for these actions are (i) the relatively low level of cross-border diversification of their operations; (ii) the high level of balance-sheet exposure to domestic sovereign debt, compared with their capital buffers; and (iii) the absence of ongoing support from foreign ownership.

The standalone credit assessments of two of the 13 banks were lowered, albeit to levels still higher than the ratings of their domestic government (the standalone credit assessments of these banks exceed the sovereign rating by one and three notches). Moody's says that these exceptions reflect factors that help mitigate the risk correlations with their respective domestic government, including high levels of cross-border diversification and low levels of sovereign debt holdings.

- LOCAL-CURRENCY DEPOSIT AND DEBT RATINGS

The lowering of the 13 banks standalone assessments led to the downgrade of 10 banks' local-currency deposit and debt ratings.

Nevertheless, as Moody's ratings also incorporate assumptions about external support through its joint-default analysis (JDA) methodology, ten banks whose standalone profiles were positioned at the sovereign rating level continue to benefit from notching uplift in their debt and deposit ratings due to systemic and parental support assumptions. The degree of uplift depends on their systemic importance or shareholder composition that includes a higher-rated parent.

WHAT COULD MOVE THE RATINGS UP/DOWN

As the key drivers of today's actions are mostly structural in nature, Moody's considers that upwards rating pressure is unlikely over the near-term. Beyond the foreseeable future, a combination of an improving operating environment, declining sovereign-risk exposures and increasing cross-border diversification may exert upwards rating pressure. An improvement in the credit risk profile of the national government could also positively influence the ratings. Conversely, deterioration in the banks' operating environments and/or a weakening of their standalone financial fundamentals could exert downwards pressure on the ratings.

LIST OF RATING ACTIONS

The following rating actions were taken:

JORDAN

- ARAB BANK

The one-notch lowering of Arab Bank's standalone credit assessment to baa2, three notches above Jordan's Ba2 sovereign debt rating, reflects Moody's acknowledgement of the bank's relative resilience to Jordanian sovereign risk, as evidenced by (i) the bank's high degree of geographical diversification beyond Jordanian borders; (ii) modest direct exposure to Jordanian government bonds; and (iii) its relatively low level of market-based funding. The rating action also takes into consideration Moody's expectation that the bank will likely face increasing problem loans and provisioning costs, owing to operating environment weaknesses in the bank's key markets.

Around three quarters of Arab Bank's group assets are outside Jordan, which limits the bank's exposure to its home market macroeconomic and financial challenges. The bank's large Saudi Arabian (40% owned) unconsolidated affiliate (Arab National Bank) provides additional diversification. Arab National Bank is booked at historical cost, but constitutes a core asset (Arab National Bank has assets of around USD31 billion against Arab Bank's group assets of USD46 billion). Arab Bank's direct and indirect exposure to Jordanian sovereign risk is also moderate, at around 40% of group Tier 1 capital. The bank is predominantly funded through deposits, has benefited from depositors' "flight to quality" during previous periods of regional instability and maintains relatively low market-based funding.

The outlook on all the bank's ratings is negative, reflecting operating environment pressures and the negative outlook on Jordan's sovereign debt rating.

- Bank Financial Strength Rating (BFSR) confirmed at C-, now mapping to a baa2 standalone credit assessment from C-/baa1

- Long-term global local-currency deposit rating downgraded to Baa2 from Baa1

- Short-term local-currency deposit ratings confirmed at Prime 2

- Long and short-term foreign-currency deposit ratings remain constrained by Jordan's foreign-currency deposit ceiling at Ba3/Not prime

- Dubai branch's long-term foreign-currency deposit rating downgraded to Baa2 from Baa1

- Dubai branch's short-term foreign-currency deposit rating confirmed at Prime 2

- HOUSING BANK FOR TRADE AND FINANCE (HBTF)

The two-notch lowering of HBTF's standalone credit assessment to ba2, in line with Jordan's Ba2 sovereign debt rating, is driven by the linkages between the bank's credit profile and sovereign credit risk. This reflects the bank's (i) high exposure to Jordanian government debt, which is equivalent to over 200% Tier 1 capital; and (ii) moderate geographical diversification outside of Jordan (foreign assets make up around a third of the bank's assets and have a proportional contribution to net income). HBTF's local-currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support, reflecting the bank's status as the second-largest Jordanian Bank, with a 15% market share by assets.

The outlook on all the bank's ratings is negative, reflecting the negative outlook on Jordan's sovereign debt rating.

- BFSR downgraded to D mapping to standalone credit assessment of ba2 from D+/baa3

- Long and short-term global local currency (GLC) deposit ratings downgraded to Ba1/Not Prime from Baa2/Prime-2

- Long and short-term foreign-currency deposit ratings remain constrained by Jordan's foreign-currency deposit ceiling at Ba3/Not Prime

LEBANON

For each Lebanese bank listed below, Moody's lowered their standalone credit assessments such that each is now in line with Lebanon's B1 sovereign debt rating. In each case, the lowering of these standalone credit profiles is driven by the linkages between the bank's credit profile and sovereign credit risk.

Moody's says although that systemic support assumptions in Lebanon are constrained by the system's high dollarization, the rating agency considers that there is a high probability that each of the three largest Lebanese bank listed below would receive systemic support, in case of need.

- BANK AUDI

Moody's lowered Bank Audi's standalone credit assessment by one notch to b1. This reflects the bank's (i) high exposure to Lebanese government debt, which is equivalent to around 350% of Tier 1 capital, when including investments in Lebanese Central Bank certificates of deposits; and (ii) moderate geographical diversification outside of Lebanon (foreign assets make up just under 30% of consolidated assets).

The confirmation of the bank's long-term GLC deposit ratings at Ba3 reflects the incorporation of one-notch of rating uplift from Moody's assessment of the high likelihood that Bank Audi (Lebanon's largest bank) would receive systemic support if needed.

The stable outlook assigned to all of Bank Audi's ratings is in line with the stable outlook on the Lebanon's debt ratings.

- BFSR downgraded to E+, mapping to a standalone credit assessment of b1, from D-/ba3

- Long-term GLC deposit rating confirmed at Ba3

- Short-term GLC deposit rating affirmed at Not Prime

- Long-term NSR confirmed at Aa1.lb

- Short-term NSR affirmed at LB1

- Long and short-term foreign-currency deposit ratings remain constrained by Lebanon's foreign-currency deposit ceiling at B1/Not Prime

- BLOM BANK

Moody's lowered Blom Bank's standalone credit assessment by one notch to b1. This reflects the bank's (i) high exposure to Lebanese government debt, which is equivalent to over 400% of Tier 1 capital, when including investments in Lebanese Central Bank certificates of deposits; and (ii) moderate geographical diversification outside of Lebanon (foreign assets make up around a third of consolidated assets).

The confirmation of the bank's long-term GLC deposit ratings at Ba3 reflects the incorporation of one-notch of rating uplift from Moody's assessment of the high likelihood that Blom Bank (Lebanon's second largest bank) would receive systemic support if needed.

The stable outlook assigned to all of Blom Bank's ratings is in line with the stable outlook on the Lebanon's debt ratings.

- BFSR downgraded to E+, mapping to a standalone credit assessment of b1, from D-/ba3

- Long-term GLC deposit rating confirmed at Ba3

- Short-term GLC deposit rating affirmed at Not Prime

- Long-term NSR confirmed at Aa1.lb

- Short-term NSR affirmed at LB1

- Long and short-term foreign-currency deposit ratings remain constrained by Lebanon's foreign-currency deposit ceiling at B1/Not Prime

- BYBLOS BANK

Moody's lowered Byblos Bank's standalone credit assessment by one notch to b1. This reflects the bank's (i) high exposure to Lebanese government debt, which is equivalent to just under 400% of Tier 1 capital, when including investments in Lebanese Central Bank certificates of deposits; and (ii) moderate geographical diversification outside of Lebanon (foreign assets make up around a third of consolidated assets).

The confirmation of the bank's long-term GLC deposit ratings at Ba3 reflects the incorporation of one-notch of rating uplift from Moody's assessment of the high likelihood that Byblos Bank (Lebanon's third largest bank) would receive systemic support if needed.

The stable outlook assigned to all of Byblos' ratings is in line with the stable outlook on the Lebanon's debt ratings.

- BFSR downgraded to E+, mapping to a standalone credit assessment of b1, from D-/ba3

- Long-term GLC deposit rating confirmed at Ba3

- Short-term GLC deposit rating affirmed at Not Prime

- Long-term foreign-currency subordinated debt rating confirmed at B1

- Long-term NSR confirmed at Aa2.lb

- Short-term NSR affirmed at LB1

- Long and short-term foreign-currency deposit ratings remain constrained by Lebanon's foreign-currency deposit ceiling at B1/Not Prime

PAKISTAN

For each Pakistani bank listed below, Moody's lowered their standalone credit assessments such that each is now in line with Pakistan's B3 sovereign debt rating. In each case, the lowering of these standalone credit profiles is driven by the linkages between the bank's credit profile and sovereign credit risk.

Moody's says that following today's rating actions, the local-currency ratings of each Pakistani bank listed below now incorporate one notch of uplift from Moody's assessment of systemic support.

- ALLIED BANK LIMITED

Moody's lowered Allied's standalone credit assessment by two notches to b3. This reflects the bank's (i) high exposure to Pakistan government debt, which account for 430% of the bank's Tier 1 capital; and (ii) geographical concentration in Pakistan's weak and volatile operating environment. Allied Bank's local currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support.

The stable outlook assigned to all of Allied's ratings is in line with the stable outlook on Pakistan's debt ratings.

- BFSR affirmed at E+ and standalone credit assessment lowered to b3 from b1

- Local-currency long-term deposit rating downgraded to B2 from B1 and short-term ratings affirmed at Not Prime

- Long-term foreign-currency deposit rating of B3 and Not Prime short-term deposit ratings are unaffected

- HABIB BANK LTD

Moody's lowered Habib's standalone credit assessment by two notches to b3. This reflects the bank's (i) high exposure to Pakistan government debt, which account for 400% of the bank's Tier 1 capital; (ii) modest geographical diversification outside of Pakistan's weak and volatile operating environment, with foreign assets contributing 7% to its pre-tax earnings. Habib Bank's local currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support.

The stable outlook assigned to all of Habib's ratings is in line with the stable outlook on Pakistan's debt ratings.

- BFSR affirmed at E+ and standalone credit assessment lowered to b3 from b1

- Local-currency long-term deposit rating downgraded to B2 from B1 and short-term ratings affirmed at Not Prime

- Long-term foreign-currency deposit rating of B3 and Not Prime short-term deposit ratings are unaffected

- MCB BANK LIMITED

MCB Bank Limited

Moody's lowered MCB's standalone credit assessment by three notches to b3. This reflects the bank's (i) high exposure to Pakistan government debt, which account for 380% of the bank's Tier 1 capital; and (ii) very limited geographical diversification outside of Pakistan's weak and volatile operating environment, with foreign assets contributing 2% to its pre-tax earnings. MCB's local currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support.

The stable outlook assigned to all of MCB's ratings is in line with the stable outlook on Pakistan's debt ratings.

- BFSR downgraded to E+, mapping to baseline credit assessment of b3, from D-/ba3

- Local-currency long-term deposit rating downgraded to B2 from Ba3 and short-term ratings affirmed at Not Prime

- Long-term foreign-currency deposit rating of B3 and Not Prime short-term deposit ratings are unaffected

- NATIONAL BANK OF PAKISTAN

Moody's lowered NBP's standalone credit assessment by three notches to b3. This reflects the bank's (i) high exposure to Pakistan government debt, which account for 252% of the bank's Tier 1 capital; and (ii) modest geographical diversification outside of Pakistan's weak and volatile operating environment, with foreign assets contributing 7% to its pre-tax earnings. NBP's local currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support.

The stable outlook assigned to all of NBP's ratings is in line with the stable outlook on Pakistan's debt ratings.

- BFSR downgraded to E+, mapping to baseline credit assessment of b3, from D-/ba3

- Local-currency long-term deposit rating downgraded to B2 from Ba3 and short-term ratings affirmed at Not Prime

- Long-term foreign-currency deposit rating of B3 and Not Prime short-term deposit ratings are unaffected

- UNITED BANK LTD

Moody's lowered United's standalone credit assessment by two notches to b3. This reflects the bank's (i) high exposure to Pakistan government debt, which account for 380% of the bank's Tier 1 capital; and (ii) modest geographical diversification outside of Pakistan's weak and volatile operating environment, with foreign assets contributing 12% to its pre-tax earnings. United Bank's local currency deposit ratings now incorporate one notch of uplift from Moody's assessment of systemic support.

The stable outlook assigned to all of United's ratings is in line with the stable outlook on Pakistan's debt ratings.

- BFSR affirmed at E+ and standalone credit assessment lowered to b3 from b1

- Local-currency long-term deposit rating downgraded to B2 from B1 and short term ratings affirmed at Not Prime

- Long-term foreign-currency deposit rating of B3 and Not Prime short-term deposit ratings are unaffected

UKRAINE

- OTP BANK UKRAINE (OTPU)

The two-notch lowering OTPU's standalone credit assessment to b2, in-line with Ukraine's B2 sovereign rating, is driven primarily by the linkages between the bank's credit profile and sovereign credit risk. This reflects the bank's (i) sizable exposure to Ukraine's government bonds, which account for over 80% of the bank's Tier 1 capital, as of year-end 2011; and (ii) the geographical concentration of the bank's business in Ukraine's weak and volatile operating environment.

The local currency deposit rating was downgraded by one notch to Ba3, but remains above Ukraine's sovereign debt rating, reflecting Moody's assumptions of the high probability of parental support. OTPU is 100% owned by OTP Bank (Ba1/Negative, D+/ba1/Negative) in Hungary. The negative outlook assigned to OTPU's deposit ratings are in line with the negative outlook on Ukraine's government's debt ratings.

- BFSR and standalone credit assessment downgraded to E+/b2, from D-/ba3

- Local-currency long-term deposit rating downgraded to Ba3 from Ba2

- National Scale Rating (NSR) affirmed at Aa1.ua

- Stable outlook on BFSR, negative outlook on all the other long-term ratings (except NSR, which does not carry an outlook)

- PRIVATBANK

The one-notch lowering of Privatbank's standalone credit assessment to b1, one notch above Ukraine's B2 sovereign rating, is driven by (i) the bank's conservative risk positioning with regard to the sovereign credit, with a track record of no direct or indirect exposure to sovereign debt; (ii) a moderate level of business diversification outside of Ukraine, with 20% of total assets related to off-shore operations, as of year-end 2011; and (iii) limited dependence on wholesale debt markets, with international facilities accounting for 10% of total non-equity funding as at year-end 2011.

The bank's deposit rating was downgraded by one notch to B1 and does not incorporate any uplift from systemic support, reflecting the limited capacity of the country's public institutions to provide such support. The negative outlook assigned to Privatbank's debt and deposit ratings are in line with the negative outlook on Ukraine's government's debt ratings.

- BFSR and standalone credit assessment downgraded to E+/b1 from D-/ba3

- Long-term local-currency deposit rating downgraded to B1 from Ba3

- Long-term foreign-currency senior unsecured debt rating confirmed at B1

- Long-term foreign-currency senior subordinated debt rating downgraded to B2 from B1

- Stable outlook on BFSR, negative outlook on all the other long-term global-scale ratings

- National Scale Rating (NSR) downgraded to Aa3.ua from Aa1.ua

- UKREXIMBANK

The two-notch lowering of Ukreximbank's standalone credit assessment to b2, in-line with Ukraine's B2 sovereign rating, is driven primarily by the linkages between the bank's credit profile and sovereign credit risk. This reflects the bank's (i) sizable exposure to Ukraine's government bonds, which account for over 40% of the bank's Tier 1 capital; (ii) geographical concentration in Ukraine's weak and volatile operating environment; and (iii) significant refinancing risks in the medium-term, as foreign-market borrowings account for 35% of Ukreximbank's total funding.

The bank's local currency deposit and debt ratings were downgraded by two notches to B2 and do not incorporate any uplift from systemic support, reflecting the limited capacity of the country's public institutions to provide such support. The negative outlook assigned to Ukreximbank's deposit and debt ratings are in line with the negative outlook on Ukraine's government's debt ratings.

- BFSR and standalone credit assessment downgraded to E+/b2 from D-/ba3

- Local-currency long-term deposit and senior unsecured debt ratings downgraded to B2 from Ba3

- Foreign-currency long-term senior unsecured debt rating downgraded to B2 from B1

- Foreign-currency long-term subordinated debt rating downgraded to B3 from B1

- B3 long-term foreign-currency deposit rating and Not Prime short-term deposit ratings are unaffected

- Stable outlook on BFSR, negative outlook on all the other long-term ratings

- RAIFFEISEN BANK AVAL

The ratings review of Raiffeisen Bank Aval, initiated on 5 April, remains ongoing. The review of the bank's standalone ratings will be concluded when Moody's concludes the review of Raiffeisen Bank International's subsidiaries.

The principle methodologies used in these ratings were Bank Financial Strength Ratings: Global Methodology published in February 2007, and Incorporation of Joint-Default Analysis into Moody's Bank Ratings: A Refined Methodology published in March 2012. Please see the Credit Policy page on www.moodys.com for a copy of these methodologies.

Moody's National Scale 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 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 ".mx" for Mexico. For further information on Moody's approach to national scale ratings, please refer to Moody's Rating Methodology published in March 2011 entitled "Mapping Moody's National Scale Ratings to Global Scale Ratings".

REGULATORY DISCLOSURES

For ratings issued on a program, series or category/class of debt, this announcement provides relevant 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 relevant regulatory disclosures in relation to the rating action on the support provider and in relation to each particular rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides relevant 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.

The deposit ratings of rated entities National Bank of Pakistan, United Bank Ltd, and Habib Bank Ltd were initiated by Moody's and were not requested by these rated entities.

Rated entities National Bank of Pakistan, United Bank Ltd, and Habib Bank Ltd or their agent(s) participated in the rating process. These rated entities or their agent(s), if any, provided Moody's access to the books, records and other relevant internal documents of the rated entities.

The ratings have been disclosed to the rated entities or their designated agent(s) and issued with no amendment resulting from that disclosure.

Information sources used to prepare the rating for Arab Bank, Housing Bank for Trade and Finance, Bank Audi, Blom Bank, and Byblos Bank are the following: parties involved in the ratings, public information, and confidential and proprietary Moody's Investors Service information.

Information sources used to prepare the rating for Allied Bank, Habib Bank, MCB Bank, National Bank of Pakistan, United Bank, Raiffeisen Bank Aval, and Ukreximbank are the following: parties involved in the ratings, and public information.

Information sources used to prepare the rating for OTP Bank Ukraine, and Privatbank are the following: parties involved in the ratings, parties not involved in the ratings, public information, and confidential and proprietary Moody's Investors Service information

Moody's considers the quality of information available on the rated entities, obligations or credits satisfactory for the purposes of issuing these ratings.

Moody's adopts all necessary measures so that the information it uses in assigning the ratings is of sufficient quality and from sources Moody's considers to be reliable including, when appropriate, independent third-party sources. However, Moody's is not an auditor and cannot in every instance independently verify or validate information received in the rating process.

Moody's Investors Service may have provided Ancillary or Other Permissible Service(s) to the rated entities or their related third parties within the two years preceding the credit rating action. Please see the special report "Ancillary or other permissible services provided to entities rated by MIS's EU credit rating agencies" on the ratings disclosure page on our website www.moodys.com for further information.

In addition to the information provided below please find on 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 each of the ratings.

Please see the ratings disclosure page on www.moodys.com for general disclosure on potential conflicts of interests.

Please see the ratings disclosure page on www.moodys.com for information on (A) MCO's major shareholders (above 5%) and for (B) further information regarding certain affiliations that may exist between directors of MCO and rated entities as well as (C) the names of entities that hold ratings from MIS that have also publicly reported to the SEC an ownership interest in MCO of more than 5%. A member of the board of directors of this rated entity may also be a member of the board of directors of a shareholder of Moody's Corporation; however, Moody's has not independently verified this matter.

Please see Moody's Rating Symbols and Definitions on the Rating Process page on www.moodys.com for further information on the meaning of each rating category and the definition of default and recovery.

Please see ratings tab on the issuer/entity page on www.moodys.com for the last rating action and the rating history.

The date on which some ratings were first released goes back to a time before Moody's ratings were fully digitized and accurate data may not be available. Consequently, Moody's provides a date that it believes is the most reliable and accurate based on the information that is available to it. Please see the ratings disclosure page on our website www.moodys.com for further information.

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.

Elena Redko
Asst Vice President - Analyst
Financial Institutions Group
Moody's Interfax Rating Agency
7th floor, Four Winds Plaza
21 1st Tverskaya-Yamskaya St.
Moscow 125047
Russia
Telephone: +7 495 228 6060
Facsimile: +7 495 228 6091

Yves J Lemay
MD - Banking
Financial Institutions Group
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Releasing Office:
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JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Moody's concludes review for downgrade on 13 banks in Jordan, Lebanon, Pakistan, Ukraine
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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