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 UK NC RMBS notes issued by Residential Mortgage Securities 19, 20, 21 and 22

27 Feb 2012

London, 27 February 2012 -- Moody's downgraded the ratings of 12 senior notes and six junior notes in four Residential Mortgage Securities transactions. All affected ratings are listed at the end of this press release.

The ratings of senior notes issued by Residential Mortgage Securities 19 Plc ("RMS19"), Residential Mortgage Securities 20 Plc ("RMS20"), Residential Mortgage Securities 21 Plc ("RMS21") and Residential Mortgage Securities 22 Plc ("RMS22") were placed on review for possible downgrade on 14th October 2011 following the downgrade of Skipton Building Society from Baa1/P-2 to Ba1/NP.

RATINGS RATIONALE

Today's downgrade is driven by (i) the exposure to payment disruption risk, (ii) the revision of collateral performance assumptions, (iii) Moody's outlook for UK non-conforming RMBS and (iv) the level of credit enhancement supporting the notes.

--- Payment Disruption Risk:

Homeloan Management Limited ("HML"), which is part of Skipton Building Society ("Skipton"), acts as servicer and as a back-up cash manager in the affected transactions. Following the downgrade of Skipton (parent company of HML) Moody's analyzed continuity of payments in the affected transactions following a potential disruption in functions performed by HML.

Moody's considers current back-up servicing arrangements insufficient to support payments in the event of servicer disruption despite presence of a back-up servicer with investment grade sponsor because the arrangements are not "warm". The back-up servicer in the affected transaction is Western Mortgage Services Ltd (NR). Parent of Western Mortgage Services Ltd is Co-Operative Bank Plc (A3/P-2). The back-up servicer targets full servicing function transfer in 120 days from the relevant appointment. In absence of servicer reports the cash managers may not be able to perform calculation necessary to process payments in a timely fashion.

In addition, current back-up cash management arrangements are not compliant with Moody's operational risk criteria. HML acts as a back-up cash manager in the affected transactions. The cash manager is Kensington Mortgage Company (KMC) (NR). Investec PLC (Ba1/NP) is the parent of KMC. KMC delegated cash management functions to Investec Bank PLC (Baa3/P-3). In particular, Moody's notes that there are no automatic termination of cash manager, no automatic appointment of back-up cash manager and the current timeline on the transfer of cash management function does not contain provision to address the timely payment of required amounts.

Moody's also believes that this risk is further exacerbated for the affected transactions because the senior notes are denominated in another currency. A failure to make timely payments to the swap counterparty could lead to a termination event under the swap documentation. Moody's concludes that maximum achievable rating for the notes in RMS20, RMS21 and RMS22 is Aa2 (sf) in consideration of this additional risk. In RMS19 the credit enhancement of 79.5% below the rated notes sufficiently mitigates the this additional risk and the maximum achievable rating is Aa1 (sf). Moody's notes that there is sufficient liquidity available in all the transactions.

--- Collateral performance assumptions

Moody's has reassessed its lifetime loss expectations in RMS20, RMS21 and RMS22 taking into account the collateral performance to date. Although overall arrears levels in the affected deals have been stable recently, the collateral performance has been worse than assumed since the latest reviews in November 2010. Collateral performance in RMS19 is in line with previous assumptions.

As of November 2011, loans more than 360 days delinquent (excluding outstanding repossessions) comprised 12.5% of the outstanding principal balance in RMS20 portfolio, 11.8% in RMS21 and 11.1% in RMS22 portfolio. Only 10% of loans that were more than 360 days delinquent as of February 2011 have improved their performance and moved into a lower arrears bucket as of November 2011. For this reason, Moody's considers loans with delinquencies exceeding 360 days as a proxy for additional future increases in repossessions and resulting losses above current losses realization trends. After considering the current amounts of realized losses and completing a roll rate and severity analysis for the portfolio Moody's has increased its lifetime expected loss assumption to 4.8% from 3.6% of the original portfolio balance in RMS20, to 6.2% from 4.9% respectively in RMS21 and to 8.3% from 6.0% respectively in RMS22. The increase of these assumptions is the driver for the downgrade of junior notes in RMS 20,21 and 22. Moody's did not change its MILAN assumptions for the affected transactions.

--- Negative Outlook for UK non-conforming RMBS

Our outlook for the collateral performance of UK non-conforming RMBS transactions in 2012 is negative. The UK economy will grow by only 0.7% in 2012, non-conforming borrowers will be more sensitive to the deteriorating economic environment than prime borrowers. Most non-conforming borrowers already use interest-only products, making it difficult for lenders to lower monthly payments if the borrower faces a disruption to income. Unemployment rates will rise to 8.5% in 2012 from a average of 8.0% in 2011. Rising unemployment will hurt non-conforming borrower performance.

Factors and Sensitivity Analysis

Expected loss assumptions remain subject to uncertainty with regards to the general economic activity, interest rates and house prices. Lower than assumed realised recovery rates or higher than assumed default rates would negatively affect some of the ratings in these transactions.

Uncertainty also stems from the timing of a servicing transfer and the credit strengths of the back-up servicer. Should a servicing transfer take longer than expected following an operational disruption or the credit strength of the back-up servicers sponsors deteriorate, the rating would be negatively affected.

As the euro area crisis continues, the rating of the structured finance notes remain exposed to the uncertainties of credit conditions in the general economy. The deteriorating creditworthiness of euro area sovereigns as well as the weakening credit profile of the global banking sector could negatively impact the ratings of the notes. For more information please refer to the Rating Implementation Guidance published on 13 February 2012 "How Sovereign Credit Quality May Affect Other Ratings". Please also refer to the recent rating actions on banks published on 15 February 2012, (please see "Moody's Reviews Ratings for European Banks" and "Moody's Reviews Ratings for Banks and Securities Firms with Global Capital Markets Operations" for more information).

In reviewing the affected transactions, Moody's used ABSROM to model the cash flows and determine the loss for each tranche. The cash flow model evaluates all default scenarios that are then weighted considering the probabilities of the lognormal distribution assumed for the portfolio default rate. In each default scenario, the corresponding loss for each class of notes is calculated given the incoming cash flows from the assets and the outgoing payments to third parties and noteholders. Therefore, the expected loss or EL for each tranche is the sum product of (i) the probability of occurrence of each default scenario; and (ii) the loss derived from the cash flow model in each default scenario for each tranche.

As such, Moody's analysis encompasses the assessment of stressed scenarios.

The principal methodology used in these ratings was Moody's Approach to Rating RMBS in Europe, Middle East, and Africa, published in October 2009. Please see the Credit Policy page on www.moodys.com a copy of this methodology.

Other Factors used in these rating are described in Global Structured Finance Operational Risk Guidelines: Moody's Approach to Analyzing Performance Disruption Risk published in June 2011.

LIST OF AFFECTED SECURITIES

Issuer: Residential Mortgage Securities 19 Plc

....GBP204M A2a Notes, Downgraded to Aa1 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....EUR183.3M A2c Notes, Downgraded to Aa1 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....MERCs Notes, Downgraded to Aa1 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

Issuer: Residential Mortgage Securities 20 PLC (RMS 20)

....GBP260.6M A2a Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....EUR176.4M A2c Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....GBP11.5M B1a Notes, Downgraded to Ba1 (sf); previously on Mar 20, 2008 Downgraded to Baa3 (sf)

....EUR21.65M B1c Notes, Downgraded to Ba1 (sf); previously on Mar 20, 2008 Downgraded to Baa3 (sf)

....MERCs Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

Issuer: Residential Mortgage Securities 21 Plc (RMS 21)

....GBP150M A3a Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....EUR254M A3c Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....GBP18M B2a Notes, Downgraded to B3 (sf); previously on Mar 20, 2008 Confirmed at B2 (sf)

....MERCs Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

Issuer: Residential Mortgage Securities 22 Plc (RMS 22)

....GBP207.6M A3a Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....EUR105M A3c Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

....GBP15M B1a Notes, Downgraded to Ba2 (sf); previously on Mar 20, 2008 Downgraded to Ba1 (sf)

....EUR13.1M B1c Notes, Downgraded to Ba2 (sf); previously on Mar 20, 2008 Downgraded to Ba1 (sf)

....GBP16M B2 Notes, Downgraded to Caa1 (sf); previously on Mar 20, 2008 Downgraded to B3 (sf)

....MERCs Notes, Downgraded to Aa2 (sf); previously on Oct 14, 2011 Aaa (sf) Placed Under Review for Possible Downgrade

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

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

Moody's did not receive or take into account a third party assessment on the due diligence performed regarding the underlying assets or financial instruments related to the monitoring of these transactions in the past six months.

Moody's considers the quality of information available on the rated entity, obligation or credit satisfactory for the purposes of issuing a rating.

Moody's adopts all necessary measures so that the information it uses in assigning a 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.

Moody's Investors Service may have provided Ancillary or Other Permissible Service(s) to the rated entity or its 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.

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.

Lyudmila Udot
Analyst
Structured Finance Group
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Barbara Rismondo
VP - Senior Credit Officer
Structured Finance Group
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Releasing Office:
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Moody's downgrades UK NC RMBS notes issued by Residential Mortgage Securities 19, 20, 21 and 22
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.

​​​​​​