Please Note
We brought you to this page based on your search query. If this isn't what you are looking for, you can continue to Search Results for ""
The maximum number of items you can export is 3,000. Please reduce your list by using the filtering tool to the left.
Close
Está por salir del sitio local de España y comenzará a navegar en el sitio global. ¿Desea continuar?
No mostrar este mensaje nuevamente
Si
No
Close
Email Research
Recipient email addresses will not be used in mailing lists or redistributed.
Recipient's
Email

Use semicolon to separate each address, limit to 20 addresses.
Enter the
characters you see
Close
Email Research
Thank you for your interest in sharing Moody's Research. You have reached the daily limit of Research email sharings.
Close
Thank you!
You have successfully sent the research.
Please note: some research requires a paid subscription in order to access.
Already a customer?
LOG IN
Don't want to see this again?
REGISTER
OR
Accept our Terms of Use to continue to Moodys.com:
​​

PLEASE READ AND SCROLL DOWN!

By clicking “I AGREE” [at the end of this document], you indicate that you understand and intend these terms and conditions to be the legal equivalent of a signed, written contract and equally binding, and that you accept such terms and conditions as a condition of viewing any and all Moody’s inform​ation that becomes accessible to you [after clicking “I AGREE”] (the “Information”).   References herein to “Moody’s” include Moody’s Corporation, Inc. and each of its subsidiaries and affiliates.

Terms of One-Time Website Use

1.            Unless you have entered into an express written contract with Moody’s to the contrary, you agree that you have no right to use the Information in a commercial or public setting and no right to copy it, save it, print it, sell it, or publish or distribute any portion of it in any form.               

2.            You acknowledge and agree that Moody’s credit ratings: (i) are current opinions of the future relative creditworthiness of securities and address no other risk; and (ii) are not statements of current or historical fact or recommendations to purchase, hold or sell particular securities.  Moody’s credit ratings and publications are not intended for retail investors, and it would be reckless and inappropriate for retail investors to use Moody’s credit ratings and publications when making an investment decision.  No warranty, express or implied, as the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of any Moody’s credit rating is given or made by Moody’s in any form whatsoever.          

3.            To the extent permitted by law, Moody’s and its directors, officers, employees, representatives, licensors and suppliers disclaim liability for: (i) any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with use of the Information; and (ii) any direct or compensatory damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud or any other type of liability that by law cannot be excluded) on the part of Moody’s or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with use of the Information.

4.            You agree to read [and be bound by] the more detailed disclosures regarding Moody’s ratings and the limitations of Moody’s liability included in the Information.     

5.            You agree that any disputes relating to this agreement or your use of the Information, whether sounding in contract, tort, statute or otherwise, shall be governed by the laws of the State of New York and shall be subject to the exclusive jurisdiction of the courts of the State of New York located in the City and County of New York, Borough of Manhattan.​​​​

I AGREE
Rating Action:

Moody's downgrades 22 Spanish RMBS notes issued by TDA CAM 5, 6, 7, 8, 9 and 10

03 Dec 2009

Approximately EUR5.4 billion of debt securities affected.

Frankfurt, December 03, 2009 -- Moody's Investors Service today downgraded the ratings of 22 classes of notes, confirmed the ratings of two classes of notes and kept on review one class of notes issued by TDA CAM 5, FTA, TDA CAM 6; FTA, TDA CAM 7, FTA, TDA CAM 8, FTA, TDA CAM 9, FTA and TDA CAM 10, FTA. A detailed list of rating actions can be found at the end of this press release.

Moody's placed the 24 affected tranches on review for possible downgrade in June 2009 either because of performance (TDA CAM 9 and 10) or because of the downgrade of Caja de Ahorros del Mediterraneo ("CAM"; TDA CAM 5, 6, 7 and 8). Today's rating actions are mainly due to worse-than-expected collateral performance and take into account an increased loss expectation in the six portfolios backing the notes. The review also took into consideration the increased commingling exposure to CAM following the downgrade, however this risk is limited by the new introduced cash sweeps which are now performed every two days (weekly for TDA CAM 10) from the collection accounts to the reinvestment accounts. Previously this sweeps were performed monthly.

Moody's previously downgraded notes issued by TDA CAM 6, 7, 8 9 and 10 in December 2008. However, the collateral performance in these transactions has deteriorated further since the last rating review, resulting in drawings on the reserve funds. So far, none of these transactions has fully drawn on the reserve fund and no principal deficiencies have been recorded. Moody's has observed a rapid increase in written-off loans, mirroring the overall deterioration in the pools' performance.

Moody's believes that the weak performance (especially in TDA CAM 10) has mainly been driven by the high loan-to-value (LTV) ratios of the securitised mortgage loans and the exposure to non-Spanish borrowers, who have been affected by difficult economic conditions such as increasing unemployment and declining house prices -- especially in coastal regions. The rating agency also understands that all of the transactions include a share of loans originated via broker, although exact numbers were not available.

Moody's has reassessed its lifetime loss expectations for the affected transactions to account for the collateral performance to date as well as its expectations for these transactions in the context of the current macroeconomic environment in Spain. As part of its analysis, Moody's has also assessed loan-by-loan information for the outstanding portfolios to determine the credit support consistent with target rating levels and the volatility of the distribution of future losses. The loss expectation and the MILAN Aaa credit enhancement (MILAN Aaa CE) are the two key parameters used by Moody's to calibrate its loss distribution curve, which is one of the core inputs in the cash flow model it uses to rate RMBS transactions.

TDA CAM 5 closed in October 2005 and the current pool factor is 62%. Delinquencies (60+ as of current pool balance (CB)) stand at 3.1% and cumulative defaulted loans (defined as 12 months in arrears for all TDA CAM transactions and measured as of original pool balance (OB)) have reached 1.4%, which means its performance is worse than what was originally assumed. The deteriorating performance has also led to a reserve fund drawing, which currently stands at 86% of its target value. On the basis of the deterioration in credit trends, Moody's has updated the portfolio expected loss assumption to 1.75% from 0.45% and revised its MILAN Aaa CE assumptions to 7.5% from 4.9%. Currently, the available credit enhancement in terms of available subordination and reserve fund (CE) for the Class A notes is below the updated MILAN Aaa CE and stands at 6%. However, Class A notes benefits from the additional support of future recoveries from currently defaulted assets and interest deferral triggers.

TDA CAM 6 closed in February 2006 and the current pool factor is 64%. Its delinquencies (60+/CB: 5.9%) and cumulative defaults (3.3% as of OB) are some of the worst within the Spanish 2006 RMBS vintage. The reserve fund is currently at only 21% of its target value. Based on this further deterioration, Moody's has updated the portfolio expected loss assumption to 3.3% from 1.7%, and revised its MILAN Aaa CE assumptions to 11% from 8%. The available CE for the Class A notes is 6.4%. Moody's confirmed the rating of the Class A1 notes and downgraded the Class A2 and A3 notes. The Class A1 notes are amortising in priority to the Class A2 notes and both are planned amortisation classes (PACs) with pre-defined amortisation schedules. The Class A3 notes (companion class) are being paid with the remaining available funds either pari-passu with Class A1 notes or, after A1 is fully repaid, pari-passu with Class A2 notes. In its cash flow analysis, Moody's has taken into consideration the faster repayment of Class A1, which led to the confirmation of its Aaa rating.

TDA CAM 7 closed in September 2006 and the current pool factor is 71%. Like TDA CAM 6, its performance is amongst the weakest across the Spanish 2006 RMBS vintage (60+/CB: 5.6%, cumulative defaults/OB: 3.1% and reserve fund at 31% of its target value). This led Moody's to update its portfolio expected loss assumption to 3.5% from 1.8% and revise its MILAN Aaa CE assumption to 11.5% from 8.5%. The available CE for the Class A notes is 8.2%. The Class A1 notes currently amortise in priority to the Class A2 and A3 notes. All Class A notes will revert to pro-rata payment when the cumulative defaults exceed 4% of OB. Moody's expects this trigger to be breached within the next quarters. However, there is a possibility that Class A1 is not fully redeemed at the next IPD on 26 February 2010 and the pro-rata trigger will be breached. Therefore Class A1 notes remain on review for possible downgrade.

TDA CAM 8 closed in January 2007 and the current pool factor is 74%. It is performing better in terms of delinquencies and defaults than TDA CAM 6 and 7 (60+/CB: 4.1%, cumulative defaults/OB: 2.2%). One possible reason for its better performance could be the lower weighted-average current LTV (62% compared to 67% for TDA CAM 6 or for TDA CAM 7). However, compared to its peers in the Spanish 2007 RMBS vintage, its performance is below average and the reserve fund is at only 21% of its target level. This led Moody's to revise its portfolio expected loss assumption to 2.63% from 1.6% and to revise its MILAN Aaa CE assumption to 9% from 7%. The available CE for the Class A notes is 5.3%.

TDA CAM 9 closed in June 2007 (pool factor: 76%) and its performance in terms of delinquencies and defaults is amongst the weakest in the Spanish RMBS sector (60+/CB: 6.0%, cumulative defaults/OB: 3.3% and reserve fund at 27% of its target value). Moody's has updated the portfolio expected loss assumption to 3.7% from 1.9% and revised its MILAN Aaa CE assumptions to 12.5% from 9%. The available CE for the class A notes is 7.1%. Class A notes will revert to pro-rata payment when the cumulative defaults exceed 4% of OB. Moody's expects this trigger to be breached within the next quarters, hence all Class A notes have been downgraded to the same rating level.

TDA CAM 10 closed in December 2007 (pool factor: 78%) and is currently performing worse than Moody's revised expectations as of the latest rating review in terms of late-stage arrears and defaults (60+ /CB: 9%, cumulative defaults/OB: 4.3%). Based on this worsening, Moody's has adjusted its portfolio expected loss assumption to 6.3% from 2.75% and revised its MILAN Aaa CE assumption to 20% from 14%. The available CE for the Class A notes is 8.7%. Since the last IPD in September 2009, the Class A pro-rata amortisation trigger has been breached. From the next IPD, the remaining three Classes of A notes will amortise pro-rata. The amortisation of the senior, mezzanine and junior notes is expected to remain sequential for the remaining life of the deals following the breach of this trigger.

None of the affected transactions have yet hit their interest deferral triggers. The interest deferral triggers for TDA CAM 5 and 6 are defined as principal deficiencies exceeding 70% of the initial amount of Class B notes. For TDA CAM 7 to 10, the interest deferral triggers are defined as the cumulative amount of loans more than 12 months in arrears exceeding a certain level of the original portfolio balance. This level is defined at 10% (Class B) for TDA CAM 7; 6.5% (Class B) and 4.5% (Class C) for TDA CAM 8; 9.5% (Class B) and 5.1% (Class C) for TDA CAM 9 and at 10% (Class B) and 6.75% (Class C) for TDA CAM 10.

Moody's ratings address the expected loss posed to investors by the legal final maturity of the notes. Moody's ratings address only the credit risks associated with the transaction. Other risks have not been addressed, but may have a significant effect on yield to investors.

Moody's` monitors the performance of the transaction using rating methodologies described in the reports "Moody's Updated Methodology for Rating Spanish RMBS," July 2008, and "Revising Default/Loss Assumptions Over the Life of an ABS/RMBS Transaction," December 2008. These reports can be found at www.moodys.com in the Rating Methodologies sub-directory under the Research & Ratings tab. Other methodologies and factors that may have been considered in the process of rating this issuer can also be found in the Rating Methodologies sub-directory on Moody's website. In addition, Moody's publishes a weekly summary of structured finance credit, ratings and methodologies, available to all registered users of our website, at www.moodys.com/SFQuickCheck.

For further information, please visit our website www.moodys.com or contact Moody's Client Service Desk (+44 20) 7772 5454.

LIST OF DETAILED RATING ACTIONS

Issuer: TDA CAM 5, FTA

- Class A, confirmed at Aaa; previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class B, downgraded to Baa3; previously on 29 June 2009, A2 placed under review for possible downgrade

Issuer: TDA CAM 6, FTA

- Class A1, confirmed at Aaa; previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class A2, downgraded to Aa2; previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class A3, downgraded to Aa2; previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class B, downgraded to B3, previously on 29 June 2009, Baa2 placed under review for possible downgrade

Issuer: TDA CAM 7, FTA

- Class A1, Aaa remains on review for possible downgrade, previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class A2, downgraded to Aa2, previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class A3, downgraded to Aa2, previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class B, downgraded to B3, previously on 29 June 2009, Baa1 placed under review for possible downgrade

Issuer: TDA CAM 8, FTA

- Class A, downgraded to Aa1, previously on 29 June 2009, Aaa placed under review for possible downgrade

- Class B, downgraded to Ba3, previously on 29 June 2009, A3 placed under review for possible downgrade

- Class C, downgraded to Caa2, previously on 29 June 2009, Ba1 placed under review for possible downgrade

- Class D, Downgraded to C, previously on 29 June 2009, Ca placed under review for possible downgrade

Issuer: TDA CAM 9, FTA

- Class A1, downgraded to Aa3, previously on 5 June 2009, Aaa placed under review for possible downgrade

- Class A2, downgraded to Aa3, previously on 5 June 2009, Aa1 placed under review for possible downgrade

- Class A3, downgraded to Aa3, previously on 5 June 2009, Aa1 placed under review for possible downgrade

- Class B, downgraded to Ba3, previously on 5 June 2009, A3 placed under review for possible downgrade

- Class C, downgraded to Ca, previously on 5 June 2009, Ba2 placed under review for possible downgrade

- Class D, downgraded to C, previously on 5 June 2009, Ca placed under review for possible downgrade

Issuer: TDA CAM 10, FTA

- Class A2, downgraded to A3, previously on 5 June 2009, Aa1 placed under review for possible downgrade

- Class A3, downgraded to A3, previously on 5 June 2009, Aa1 placed under review for possible downgrade

- Class A4, downgraded to A3, previously on 5 June 2009, Aa1 placed under review for possible downgrade

- Class B, downgraded to B3, previously on 5 June 2009, Baa2 placed under review for possible downgrade

- Class C, downgraded to C, previously on 5 June 2009, B3 placed under review for possible downgrade

London
Barbara Rismondo
VP - Senior Credit Officer
Structured Finance Group
Moody's Investors Service Ltd.
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Frankfurt
Johannes Ebner
Asst Vice President - Analyst
Structured Finance Group
Moody's Deutschland GmbH
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Moody's downgrades 22 Spanish RMBS notes issued by TDA CAM 5, 6, 7, 8, 9 and 10
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.

CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. AND ITS RATINGS AFFILIATES (“MIS”) ARE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MOODY’S PUBLICATIONS MAY INCLUDE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT OR IMPAIRMENT. SEE MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY’S OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY’S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY’S ANALYTICS, INC. CREDIT RATINGS AND MOODY’S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY’S PUBLICATIONS COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS AND PUBLISHES MOODY’S PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE.

MOODY’S CREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY’S CREDIT RATINGS OR MOODY’S PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY’S PRIOR WRITTEN CONSENT.

CREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.

All information contained herein is obtained by MOODY’S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS” without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating 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 or in preparing the Moody’s publications.

To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY’S.

To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.

NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY’S IN ANY FORM OR MANNER WHATSOEVER.

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.

​​​​​​