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Rating Action:

Moody's downgrades $986 million of Subprime RMBS issued by ACE in 1999 through 2004

15 Mar 2011

New York, March 15, 2011 -- Moody's Investors Service has downgraded the ratings of 101 tranches and confirmed the ratings of 2 tranches from 23 Subprime deals issued by ACE. The collateral backing these deals primarily consists of first-lien, fixed and adjustable rate Subprime residential mortgages.

RATINGS RATIONALE

The actions are a result of deteriorating performance of Subprime pools securitized before 2005. Although most of these pools have paid down significantly, the remaining loans are affected by the housing and macroeconomic conditions that remain under duress.

The actions reflect Moody's updated loss expectations on Subprime pools securitized before 2005.

The principal methodology used in these ratings was "Pre-2005 US RMBS Surveillance Methodology" published in January 2011. 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.

Moody's final rating actions are based on current ratings, level of credit enhancement, collateral performance and updated pool-level loss expectations relative to current level of credit enhancement. Moody's took into account credit enhancement provided by seniority, cross-collateralization, excess spread, time tranching, and other structural features within the senior note waterfalls.

The above mentioned approach "Pre-2005 US RMBS Surveillance Methodology" is adjusted slightly when estimating losses on pools left with a small number of loans to account for the volatile nature of small pools. Even if a few loans in a small pool become delinquent, there could be a large increase in the overall pool delinquency level due to the concentration risk. To project losses on pools with fewer than 100 loans, Moody's first estimates a "baseline" average rate of new delinquencies of 11% for pools originated and securitized before 2005. The baseline rate is generally higher than the average rate of new delinquencies for larger pools. Once the baseline rate is set, further adjustments are made based on 1) the number of loans remaining in the pool and 2) the level of current delinquencies in the pool. The fewer the number of loans remaining in the pool, the higher the volatility in performance. Once the loan count in a pool falls below 75, the rate of delinquency is increased by 1% for every loan less than 75. For example, for a pool with 74 loans from the 2004 vintage, the adjusted rate of new delinquency would be 11.11%. In addition, if the current delinquency level in a small pool is low, future delinquencies are expected to reflect this trend. To account for that, the rate calculated above is multiplied by a factor ranging from 0.85 to 2.25 for current delinquencies ranging from less than 10% to greater than 50% respectively. Delinquencies for subsequent years and ultimate expected losses are projected using the approach described in the methodology publication.

The primary source of assumption uncertainty is the current macroeconomic environment, in which unemployment levels remain high, and weakness persists in the housing market. Overall, Moody's assumes a further 5% decline in home prices with stabilization in late 2011, accompanied by continued stress in national employment levels through that timeframe.

For more information please see www.moodys.com.

Moody's Investors Service received and took into account one or more third party due diligence reports on the underlying assets or financial instruments in this transaction and the due diligence reports had a neutral impact on the rating.

Complete rating actions are as follows:

Issuer: ACE Securities Corp. Home Equity Loan 1999-LB2

A, Confirmed at Aaa (sf); previously on Apr 8, 2010 Aaa (sf) Placed Under Review for Possible Downgrade

M-1, Downgraded to Aa3 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

M-2, Downgraded to Baa1 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2001-AQ1 Asset Backed Pass-Through Certificates

Cl. M-2, Downgraded to Baa3 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Issuer: Ace Securities Corp. Home Equity Loan Trust, Series 2002-HE1

Cl. M-1, Downgraded to B3 (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Ace Securities Corp. Home Equity Loan Trust, Series 2002-HE2

Cl. M-1, Downgraded to Baa3 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Ba3 (sf); previously on Apr 8, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ca (sf); previously on Apr 8, 2010 Caa1 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2002-HE3

Cl. M-1, Downgraded to B2 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-FM1

Cl. M-1, Downgraded to Ba3 (sf); previously on Apr 8, 2010 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Ca (sf); previously on Apr 8, 2010 A1 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to C (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Ba1 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 B1 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-HE1

Cl. M-1, Downgraded to B2 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Ca (sf); previously on Apr 8, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to C (sf); previously on Apr 8, 2010 Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-HS1

Cl. M-2, Downgraded to Baa1 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ba1 (sf); previously on Apr 8, 2010 Aa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to B3 (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to Ca (sf); previously on Apr 8, 2010 Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-NC1

Cl. A-1, Downgraded to Aa1 (sf); previously on Oct 27, 2003 Assigned Aaa (sf)

Cl. M-1, Downgraded to Caa1 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to C (sf); previously on Apr 8, 2010 B1 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-OP1

Cl. M-1, Downgraded to Ba1 (sf); previously on Apr 8, 2010 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Caa3 (sf); previously on Apr 8, 2010 Aa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ca (sf); previously on Apr 8, 2010 A1 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 Ba1 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2003-TC1

Cl. M-1, Downgraded to Baa1 (sf); previously on Aug 29, 2003 Assigned Aa2 (sf)

Cl. M-2, Downgraded to B3 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ca (sf); previously on Apr 8, 2010 Ba1 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-FM1

2004-FM1-M1, Downgraded to Baa3 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

2004-FM1-M2, Downgraded to Caa2 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

2004-FM1-M3, Downgraded to C (sf); previously on Apr 8, 2010 A3 (sf) Placed Under Review for Possible Downgrade

2004-FM1-M4, Downgraded to C (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

2004-FM1-M6, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-FM2

2004FM2-M1, Downgraded to Caa1 (sf); previously on Apr 8, 2010 Aa1 (sf) Placed Under Review for Possible Downgrade

2004FM2-M2, Downgraded to C (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

2004FM2-M3, Downgraded to C (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

2004FM2-M4, Downgraded to C (sf); previously on Apr 8, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

2004FM2-M5, Downgraded to C (sf); previously on Apr 8, 2010 Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-HE1

Cl. M-2, Downgraded to Ba1 (sf); previously on Feb 3, 2009 Downgraded to Baa3 (sf)

Cl. M-3, Downgraded to Caa3 (sf); previously on Apr 8, 2010 Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-HE2

Cl. M-1, Downgraded to Baa1 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to B1 (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Caa3 (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to Ca (sf); previously on Apr 8, 2010 B2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-HE3

Cl. M-1, Downgraded to A1 (sf); previously on Nov 29, 2004 Assigned Aa1 (sf)

Cl. M-2, Downgraded to B1 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to B2 (sf); previously on Apr 8, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to Caa3 (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 B1 (sf) Placed Under Review for Possible Downgrade

Cl. M-7, Downgraded to C (sf); previously on Apr 8, 2010 Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-HE4

Cl. M-1, Downgraded to Baa2 (sf); previously on Mar 4, 2005 Assigned Aa1 (sf)

Cl. M-2, Downgraded to Caa1 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Caa3 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 B3 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-HS1

Cl. A-2, Downgraded to A3 (sf); previously on Apr 8, 2010 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. A-3, Downgraded to A3 (sf); previously on Apr 8, 2010 Aaa (sf) Placed Under Review for Possible Downgrade

Cl. M-1, Downgraded to Caa2 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to C (sf); previously on Apr 8, 2010 Caa1 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-IN1

Cl. A-1, Downgraded to Aa2 (sf); previously on Aug 13, 2004 Assigned Aaa (sf)

Cl. M-1, Downgraded to B2 (sf); previously on Nov 10, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Caa3 (sf); previously on Nov 10, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ca (sf); previously on Nov 10, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Nov 10, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Nov 10, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Nov 10, 2010 Ba2 (sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to C (sf); previously on Nov 10, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-OP1

Cl. M-1, Downgraded to Ba3 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to Caa3 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to Ca (sf); previously on Apr 8, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 Ca (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-RM1

Cl. M-1, Downgraded to B3 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to C (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to C (sf); previously on Apr 8, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to C (sf); previously on Apr 8, 2010 B3 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-RM2

Cl. M-2, Downgraded to Ba2 (sf); previously on Apr 8, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to Caa3 (sf); previously on Apr 8, 2010 A1 (sf) Placed Under Review for Possible Downgrade

Cl. M-4, Downgraded to C (sf); previously on Apr 8, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. M-5, Downgraded to C (sf); previously on Apr 8, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. M-6, Downgraded to C (sf); previously on Apr 8, 2010 Ba2 (sf) Placed Under Review for Possible Downgrade

Cl. M-7, Downgraded to C (sf); previously on Apr 8, 2010 B3 (sf) Placed Under Review for Possible Downgrade

Issuer: Ace Securities Corp. Home Equity Loan Trust. Series 2001-HE1

Cl. M-2, Confirmed at A2 (sf); previously on Apr 8, 2010 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Downgraded to B3 (sf); previously on Apr 8, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found at:

Excel: http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF239852

A list of updated estimated pool losses and sensitivity analysis is being posted on an ongoing basis for the duration of this review period and may be found at:

Excel: http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237255

REGULATORY DISCLOSURES

Information sources used to prepare the credit rating are the following: parties involved in the ratings, public information, confidential and proprietary Moody's Investors Service information, and confidential and proprietary Moody's Analytics information.

Moody's Investors Service considers the quality of information available on the issuer or obligation satisfactory for the purposes of maintaining a credit rating.

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.

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

The date on which some Credit Ratings were first released goes back to a time before Moody's Investors Service's Credit Ratings were fully digitized and accurate data may not be available. Consequently, Moody's Investors Service 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 the Credit Policy page on Moodys.com for the methodologies used in determining ratings, further information on the meaning of each rating category and the definition of default and recovery.

New York
Jayesh Joseph
Associate Analyst
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

New York
Amelia (Amy) Tobey
VP - Senior Credit Officer
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's Investors Service
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's downgrades $986 million of Subprime RMBS issued by ACE in 1999 through 2004
No Related Data.
© 2020 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/OR ITS CREDIT RATINGS AFFILIATES ARE MOODY'S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND INFORMATION PUBLISHED BY MOODY'S (COLLECTIVELY, "PUBLICATIONS") MAY INCLUDE SUCH  CURRENT OPINIONS. MOODY'S INVESTORS SERVICE 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 INVESTORS SERVICE CREDIT RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS, NON-CREDIT ASSESSMENTS ("ASSESSMENTS"), AND  OTHER 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. AND/OR ITS AFFILIATES. MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND  PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND  PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY'S ISSUES ITS CREDIT RATINGS, ASSESSMENTS AND OTHER OPINIONS AND PUBLISHES  ITS 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.

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Additional terms for Japan only: Moody's Japan K.K. ("MJKK") is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moody's Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody's SF Japan K.K. ("MSFJ") is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization ("NRSRO"). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.

MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any 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 JPY250,000,000.

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

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