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Rating Action:

Moody's lowers ratings of 94 Notes issued by 23 structured finance CDO transactions

24 Apr 2009

New York, April 24, 2009 -- Moody's Investors Service announced today that it has downgraded its ratings of 94 Notes issued by 23 collateralized debt obligation transactions which consist of significant exposure to one or more of Alt-A, Option-ARM and subprime RMBS securities, CLOs, or CMBS. Moody's explained that the rating actions listed below reflect certain updates and projections and recent rating actions on underlying assets on these asset classes as described below. Some of the deals have also experienced an Event of Default.

Moody's revised loss projections for Alt-A RMBS securities which were described in a press release titled "Moody's Updated Loss Projections for '06 and '07 Alt-A RMBS," published on January 22, 2009. According to the press release, on average, Moody's is now projecting cumulative losses of about 20% for 2006 securitizations and about 24% for 2007 securitizations. For more details on the revised loss projections and Moody's updated Alt-A surveillance methodology, please see "Alt-A RMBS Loss Projection Update: January 2009," available on Moodys.com. Moody's revised loss projections for Option ARMs RMBS securities issued in the US since 2004 which were described in a press release titled "Moody's updates loss projections for Option ARMs RMBS" published on February 5, 2009. According to the press release, on average, Moody's is now projecting cumulative losses of 27% for 2006 and 30% for 2007 vintage Option ARM securitizations. For more details on the revised loss projections and Moody's updated Option ARMs surveillance methodology, please see "Option ARMs Loss Projection Update: February 2009" available on Moodys.com.

Moody's revised loss projections for subprime RMBS issued from 2005 to 2007 were described in a press release titled "2005-7 subprime RMBS on downgrade review" published on February 26, 2009. The revised loss projection for 2006 vintage subprime pools is expected to fall within the range of 28% to 32% of the original balance of such pools, whereas Moody's previous estimate was 22%. For 2005 and 2007 pools, such projections are expected to range from 12% to 14% and 33% to 37% of original balance, respectively.

A review of all U.S. commercial mortgage backed securities (CMBS) conduit and fusion transactions rated during the period from 2006 through 2008, and all large loan and single borrower transactions regardless of vintage was concluded recently. The review was announced in a Press Release titled "Moody's announces review of Certain U.S. CMBS Ratings " on February 5, 2009.

Moody's announced revisions and updates to certain key assumptions, including Default Probability and Diversity Score, that it uses to rate and monitor collateralized loan obligations (CLOs) in a Press Release titled "Moody's updates key assumptions for rating CLOs" published on February 4, 2009. The completion of the first stage of its two-stage review of U.S. and EMEA cash flow CLOs was announced on March 27, 2009. As of March 23, Moody's had downgraded approximately 2,071 tranches from 668 transactions.

In addition, Moody's explained that the rating actions taken today incorporate the application of revised and updated key modeling parameter assumptions that Moody's uses to rate and monitor ratings of SF CDOs. The revisions affect the three key parameters in Moody's model for rating SF CDOs: asset correlation, default probability and recovery rate. Moody's announced the changes to these assumptions in a press release titled "Moody's Updates its Key Assumptions for Rating Structured Finance CDOs," published on December 11, 2008.

Moody's initially analyzed and continues to monitor these transactions using primarily the methodology and its supplements for ABS CDOs as described in Moody's Special Report below:

- Moody's Approach to Rating SF CDOs (March 2009)

This report can be found at www.moodys.com in the Credit Policy & Methodologies directory, in the Ratings Methodologies subdirectory. Other methodologies and factors that may have been considered in the process of rating this issue can also be found in the Credit Policy & Methodologies directory.

Today's rating actions are as follows:

Adams Square Funding II, Ltd.

U.S. $600,000,000 Class A1 Floating Rate Notes Due 2047, Downgraded to C; previously on 8/26/2008 Downgraded to Ca

ARLO VII Series 2007-1 (SABS)

EUR 21,000,000 Variable Secured Limited Recourse Credit-Linked Notes due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and Placed Under Review for Possible Downgrade

Bernoulli High Grade CDO I, Ltd.

Class A1-A First Priority Senior Secured Floating Rate Notes, Downgraded to Ca; previously on 12/16/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

Class A-1B First Priority Senior Secured Floating Rate Notes, Downgraded to B3; previously on 12/16/2008 Downgraded to Ba3 and remains on Review for Possible Downgrade

Class A-2 Second Priority Senior Secured Floating Rate Notes, Downgraded to C; previously on 10/27/2008 Downgraded to Ca

Class B Third Priority Senior Secured Floating Rate Notes, Downgraded to C; previously on 10/27/2008 Downgraded to Ca

Cairn Mezz ABS CDO III Limited

U.S. $550,000,000 Class A1-VF Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $75,000,000 Class A2A Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Ca

U.S. $148,000,000 Class A2B Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Ca

U.S. $67,000,000 Class B1 Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $11,000,000 Class B2 Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $13,000,000 Class C1 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $18,750,000 Class C2 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

U.S. $17,000,000 Class C3 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

U.S. $17,000,000 Class D1 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

U.S. $17,000,000 Class D2 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

U.S. $17,000,000 Class D3 Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

U.S. $9,250,000 Class E Mezzanine Secured Deferrable Interest Floating Rate Notes Due 2047, Downgraded to C; previously on 5/21/2008 Downgraded to Ca

C-BASS CBO XVIII Ltd.

U.S. $346,000,000 Class A-1 First Priority Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $150,000,000 Class A-2 First Priority Senior Secured Fixed Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $46,500,000 Class B Second Priority Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 4/22/2008 Downgraded to Ca

Charles Fort CDO I, Ltd.

U.S.$220,000,000 Class A-1 First Priority Senior Secured Floating Rate Notes due July 9, 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S.$60,000,000 Class A-2 Second Priority Senior Secured Floating Rate Notes due July 9, 2047, Downgraded to C; previously on 4/22/2008 Downgraded to Ca

U.S.$50,000,000 Class B Third Priority Senior Secured Floating Rate Notes due July 9, 2047, Downgraded to C; previously on 4/22/2008 Downgraded to Ca

U.S.$24,000,000 Class C Fourth Priority Mezzanine Secured Floating Rate Deferrable Interest Notes due July 9, 2047, Downgraded to C; previously on 4/22/2008 Downgraded to Ca

Clifton I CDO, Ltd.

U.S. $1,200,000,000 Class A-1 First Priority Senior Secured Floating Rate Delayed Draw Notes Due 2052, Downgraded to C; previously on 12/11/2008 Downgraded to Caa1 and remains on Review for Possible Downgrade

U.S. $55,000,000 Class A-2 Second Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 6/3/2008 Downgraded to Ca

U.S. $65,000,000 Class A-3 Third Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 6/3/2008 Downgraded to Ca

U.S. $67,000,000 Class A-4 Fourth Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 6/3/2008 Downgraded to Ca

U.S. $65,000,000 Class B Fifth Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 6/3/2008 Downgraded to Ca

Cookson SPC Series 2007-2LAC

EUR 10,000,000 Series 2007-2LAC Notes Due 2046, Downgraded to C; previously on 5/8/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

HG-COLL 2007-1 Ltd.

U.S. $830,000,000 Class A-1LA Floating Rate Notes Due April 2052, Downgraded to C; previously on 12/11/2008 Downgraded to Caa1 and remains on Review for Possible Downgrade

U.S. $95,000,000 Class A-1LB Floating Rate Notes Due April 2052, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $37,000,000 Class A-2L Floating Rate Notes Due April 2052, Downgraded to C; previously on 5/9/2008 Downgraded to Ca

Istana High Grade ABS CDO I, Ltd.

U.S.$600,000,000 Class A-1 First Priority Delayed Draw Floating Rate Notes Due 2048, Downgraded to Ca; previously on 12/16/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

Ixion 2007 Series 31

U.S. $13,000,000 Floating Rate Portfolio Credit Linked Secured Notes due 2037, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and Placed Under Review for Possible Downgrade

Kleros Preferred Funding VIII, Ltd.

U.S. $2,400,000,000 Class A-1A First Priority Senior Secured Delayed Draw Floating Rate Notes Due 2052, Downgraded to Ca; previously on 12/11/2008 Downgraded to Caa1 and remains on Review for Possible Downgrade

U.S. $150,000,000 Class A-1B Second Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 12/11/2008 Downgraded to Caa2 and remains on Review for Possible Downgrade

U.S. $180,000,000 Class A-2 Third Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $144,000,000 Class A-3 Fourth Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 5/30/2008 Downgraded to Ca

U.S. $52,500,000 Class B Fifth Priority Senior Secured Floating Rate Notes Due 2052, Downgraded to C; previously on 5/30/2008 Downgraded to Ca

U.S. $19,500,000 Class X Senior Secured Floating Rate Notes Due 2013, Downgraded to C; previously on 5/30/2008 Downgraded to Ca

Lexington Capital Funding V Ltd.

U.S.$246,000,000 Class A-1 First Priority Senior Secured Floating Rate Notes Due 2051, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S.$123,000,000 Class A-2 Second Priority Senior Secured Floating Rate Notes Due 2051, Downgraded to C; previously on 6/2/2008 Downgraded to Ca

U.S.$91,500,000 Class A-3 Third Priority Senior Secured Floating Rate Notes Due 2051, Downgraded to C; previously on 6/2/2008 Downgraded to Ca

U.S.$42,000,000 Class B Fourth Priority Senior Secured Floating Rate Notes Due 2051, Downgraded to C; previously on 6/2/2008 Downgraded to Ca

U.S.$40,000,000 Class C Fifth Priority Mezzanine Secured Deferrable Floating Rate Notes Due 2051, Downgraded to C; previously on 3/26/2008 Downgraded to Ca

U.S.$28,000,000 Class D Sixth Priority Mezzanine Secured Deferrable Floating Rate Notes Due 2051, Downgraded to C; previously on 3/26/2008 Downgraded to Ca

U.S.$14,225,000 Class E Seventh Priority Mezzanine Secured Deferrable Floating Rate Notes Due 2051, Downgraded to C; previously on 3/26/2008 Downgraded to Ca

Libertas Preferred Funding V, Ltd.

U.S. $360,000,000 Class A-1 Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $30,000,000 Class A-2 Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $66,000,000 Class A-3 Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $40,500,000 Class B Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $31,500,000 Class C Mezzanine Secured Deferrable Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $23,000,000 Class D Mezzanine Secured Deferrable Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $22,000,000 Class E Mezzanine Secured Deferrable Floating Rate Notes Due 2047, Downgraded to C; previously on 5/23/2008 Downgraded to Ca

U.S. $20,000,000 Class X Senior Secured Floating Rate Notes Due 2013, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

Magnolia Finance II plc., Series 2006-5

Series 2006-5A, Downgraded to C; previously on 12/16/2008 Downgraded to B3 and remains on Review for Possible Downgrade

Series 2006-5B, Downgraded to C; previously on 12/16/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

Series 2006-5CE, Downgraded to C; previously on 4/30/2008 Downgraded to Ca

Series 2006-5CG, Downgraded to C; previously on 4/30/2008 Downgraded to Ca

Series 2006-5CU, Downgraded to C; previously on 4/30/2008 Downgraded to Ca

Parapet 2006 Ltd.

U.S.$137,500,000 Class A Floating Rate Notes Due 2045, Downgraded to C; previously on 12/16/2008 Downgraded to B3 and remains on Review for Possible Downgrade

Ridgeway Court Funding I, Ltd.

Class A1M Notes, Downgraded to C; previously on 12/16/2008 Downgraded to B2 and remains on Review for Possible Downgrade

Class A1Q Notes, Downgraded to C; previously on 12/16/2008 Downgraded to B2 and remains on Review for Possible Downgrade

Class A2 Notes, Downgraded to C; previously on 12/16/2008 Downgraded to Ca

Class A3 Notes, Downgraded to C; previously on 2/5/2008 Downgraded to Ca

Silver Elms CDO II Limited

U.S.$873,600,000 Class A-1M Floating Rate Senior Secured Notes due 2051, Downgraded to C; previously on 12/11/2008 Downgraded to Caa1 and remains on Review for Possible Downgrade

U.S.$151,400,000 Class A-1Q Floating Rate Senior Secured Notes due 2051, Downgraded to C; previously on 12/11/2008 Downgraded to Caa1 and remains on Review for Possible Downgrade

U.S.$87,500,000 Class A-2 Floating Rate Senior Secured Notes due 2051, Downgraded to C; previously on 5/29/2008 Downgraded to Ca

U.S.$74,000,000 Class A-3 Floating Rate Senior Secured Notes due 2051, Downgraded to C; previously on 5/29/2008 Downgraded to Ca

U.S.$28,000,000 Class B Floating Rate Subordinate Secured Notes due 2051, Downgraded to C; previously on 5/29/2008 Downgraded to Ca

South Coast Funding IX Ltd

$250,000,000 Class A-1B First Priority Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/18/2008 Downgraded to Ca

$47,000,000 Class A-2 Second Priority Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/18/2008 Downgraded to Ca

$37,500,000 Class B Third Priority Senior Secured Floating Rate Notes Due 2047, Downgraded to C; previously on 5/18/2008 Downgraded to Ca

$34,500,000 Class C Fourth Priority Mezzanine Secured Floating Rate Deferrable Notes Due 2047, Downgraded to C; previously on 3/26/2008 Downgraded to Ca

Super Senior Swap, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

STACK 2007-2 Ltd.

U.S. $330,000,000 Class A-1 Senior Variable Funding Floating Rate Notes Due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S. $138,000,000 Class A-2 Floating Rate Notes Due 2047, Downgraded to C; previously on 6/9/2008 Downgraded to Ca

U.S. $46,800,000 Class B Floating Rate Notes Due 2047, Downgraded to C; previously on 6/9/2008 Downgraded to Ca

Toro ABS CDO II, LLC

U.S.$885,000,000 Class A-1 First Priority Senior Secured Floating Rate Delayed Draw Notes Due June 2043, Downgraded to Ca; previously on 12/16/2008 Downgraded to Caa2 and remains on Review for Possible Downgrade

US$56,000,000 Class A-2 Second Priority Senior Secured Floating Rate Notes Due June 2043, Downgraded to C; previously on 7/9/2008 Downgraded to Ca

US$24,000,000 Class B Third Priority Senior Secured Floating Rate Notes Due June 2043, Downgraded to C; previously on 5/9/2008 Downgraded to Ca

US$7,000,000 Class C Fourth Priority Senior Secured Floating Rate Notes Due June 2043, Downgraded to C; previously on 5/9/2008 Downgraded to Ca

UBS Euro Note Programme AMPST 2007-1

U.S. $20,000,000 Floating Rate Credit Linked Notes due 2047, Downgraded to C; previously on 12/11/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

West Coast Funding I, Ltd.

U.S.$ 1,187,950,000 Class A-1a Floating Rate Notes Due 2041, Downgraded to Ca; previously on 12/16/2008 Downgraded to Ba3 and remains on Review for Possible Downgrade

U.S.$ 1,187,950,000 Class A-1b Floating Rate Notes Due 2041, Downgraded to Ca; previously on 12/16/2008 Downgraded to Ba3 and remains on Review for Possible Downgrade

U.S.$100,000 Class A-1v Floating Rate Notes Due 2041, Downgraded to Ca; previously on 12/16/2008 Downgraded to Ba3 and remains on Review for Possible Downgrade

U.S.$81,000,000 Class A-2 Floating Rate Notes Due 2041, Downgraded to C; previously on 12/16/2008 Downgraded to B1 and remains on Review for Possible Downgrade

U.S.$81,000,000 Class A-3 Floating Rate Notes Due 2041, Downgraded to C; previously on 12/16/2008 Downgraded to B1 and remains on Review for Possible Downgrade

U.S.$54,000,000 Class B Floating Rate Notes Due 2041, Downgraded to C; previously on 12/16/2008 Downgraded to Caa2 and remains on Review for Possible Downgrade

U.S.$60,750,000 Class C Deferrable Floating Rate Notes Due 2041, Downgraded to C; previously on 12/16/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

U.S.$33,750,000 Class D Deferrable Floating Rate Notes Due 2041, Downgraded to C; previously on 5/8/2008 Downgraded to Caa3 and Placed Under Review for Possible Downgrade

U.S.$10,000,000 Combination Notes Due 2041, Downgraded to C; previously on 12/16/2008 Downgraded to Caa3 and remains on Review for Possible Downgrade

New York
Stephen Lioce
Senior Vice President
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

New York
Sindhu Veluri
Asst Vice President - Analyst
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's lowers ratings of 94 Notes issued by 23 structured finance CDO transactions
No Related Data.
© 2022 Moody’s Corporation, Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors and affiliates (collectively, “MOODY’S”). All rights reserved.

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Moody’s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody’s Corporation (“MCO”), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody’s Investors Service, Inc. have, prior to assignment of any credit rating, agreed to pay to Moody’s Investors Service, Inc. for credit ratings opinions and services rendered by it fees ranging from $1,000 to approximately $5,000,000. MCO and Moody’s Investors Service also maintain policies and procedures to address the independence of Moody’s Investors Service credit ratings and credit rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold credit ratings from Moody’s Investors Service and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at www.moodys.com under the heading “Investor Relations — Corporate Governance — Director and Shareholder Affiliation Policy.”

Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided only to “wholesale clients” within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors.

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

MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any credit rating, agreed to pay to MJKK or MSFJ (as applicable) for credit ratings opinions and services rendered by it fees ranging from JPY100,000 to approximately JPY550,000,000.

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

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