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Rating Action:

Moody's places Russia's Baa3 ratings and Ukraine's B3 ratings on review for downgrade

25 Feb 2022

London, 25 February 2022 -- Moody's Investors Service ("Moody's") has today placed the Government of Russia's Baa3 long-term issuer (domestic and foreign currency) and senior unsecured (domestic and foreign currency) ratings as well as the P-3 Other Short Term (domestic currency) rating on review for downgrade. At the same time, Moody's has placed the Government of Ukraine's B3 foreign- and domestic-currency long-term issuer ratings and foreign-currency senior unsecured rating on review for downgrade.

These reviews were triggered by Russia's further military operation in Ukraine which started on 24 February 2022. These events represent a significant further elevation of the geopolitical risks that Moody's had previously highlighted, which is being accompanied by additional and more severe sanctions on Russia, potentially including those that could impact sovereign debt repayment.

The ultimate severity of the impact of new sanctions on Russia's credit profile will depend on their scope, the sectors targeted and the degree of coordination between Western countries. With respect to Ukraine, an extensive conflict could pose a risk to the government's liquidity and external positions given Ukraine's sizeable external maturities in the coming years and the reliance of its economy on foreign-currency funding.

Please click on this link https://www.moodys.com/viewresearchdoc.aspx?docid=PBC_ARFTL463212 for the List of Affected Credit Ratings. This list is an integral part of this Press Release and identifies each affected issuer.

Please see the individual country-specific statements below for more detailed information relating to the rating rationale for each sovereign.

MOODY'S PLACES RUSSIA'S Baa3 RATINGS ON REVIEW FOR DOWNGRADE

Moody's has today placed the Government of Russia's Baa3 long-term issuer (domestic and foreign currency) and senior unsecured (domestic and foreign currency) ratings as well as the P-3 Other Short-Term (domestic currency) rating on review for downgrade.

The decision to place the ratings on review for downgrade reflects the negative credit implications for Russia's credit profile from the additional and more severe sanctions being imposed.

The review period will allow Moody's to evaluate the scale of the military conflict and the impact of further sanctions including their scope, the sectors targeted and the degree of coordination between Western countries and ultimate severity of their impact on Russia's credit profile. In this context, Moody's will also take into account the degree to which Russia's substantial buffers are able to mitigate the disruption brought about by the new sanctions and protracted military conflict. Moody's will look to conclude the review when these credit implications become more clear, particularly when the impact of further sanctions takes shape in the coming days or weeks.

Serious concerns around Russia's ability to manage the disruptive impact of new sanctions on its economy, public finances and financial system may result in a downgrade of the ratings. However, in the low likelihood that Moody's concluded that significant new economic and financial sanctions were to have a very limited impact on Russia's economy and financial buffers, one possible outcome of the review will be to confirm Russia's ratings with a negative outlook.

Russia's local- and foreign-currency country ceilings remain unchanged at Baa1 and Baa2, respectively. The two-notch gap between the local-currency ceiling and the sovereign rating reflects the relatively large footprint of the government in the economy and financial system, relatively strong reliance on a common revenue source from the commodity sector and elevated political risk, which is set against moderate policy predictability and limited external imbalances. The one-notch gap between the foreign-currency ceiling and the local-currency ceiling reflects low external debt and a moderately open capital account, which reduce the incentives to impose transfer and convertibility restrictions.

RATINGS RATIONALE / FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

RATIONALE FOR INITIATING THE REVIEW FOR DOWNGRADE ON RUSSIA's Baa3 RATINGS

The imposition of severe and co-ordinated sanctions that materially disrupt the economy, public finances and the financial system for a sustained period and therefore could impair Russia's ability to service and refinance its debt would pose immediate risks to the credit profile. For example, sanctions that hinder Russian banks' access to foreign currencies or international payment systems, such as SWIFT, would likely have a material impact on the economy and financial system. The sanctioning of large Russian banks will effectively block the institutions from participating in the global financial system and make it exceptionally difficult to engage in international transactions. There remains some uncertainty around the effectiveness of any workarounds in such a scenario. Russian banks may also struggle to find counterparties to help facilitate cross-border transactions given the compliance risk of dealing with a sanctioned entity.

Despite ample liquidity relative to forthcoming external debt repayments and a clear track record on the part of Russia to service its debt, new sanctions which restrict the ability of Russian financial institutions to transact with foreign counterparties could result in a scenario where there are technical challenges to executing cross-border payments in a timely manner, including potentially for sovereign debt payments. Sanctions that lead to delays in the repayment of debt obligations may result in a default under Moody's definition and a downgrade of the ratings. Moody's considers this to be an unlikely scenario as sanctions by Western countries are likely to include exceptions for sovereign debt payments. Recently announced sanctions by the United States (US, Aaa stable) on sovereign debt that apply only to new debt issuance support this view.

While Russia´s ability to respond to and operate under sanctions has strengthened over the past years given its accumulated buffers and an enhanced policy toolkit, the scope of sanctions will likely be much more severe than Moody's previously anticipated, reducing the effectiveness of these buffers. Fiscal buffers are substantial, with reserves in the National Wealth Fund amounting to around 11% of GDP at end-2021. Furthermore, the accumulation of large foreign-exchange buffers has strengthened the country's external position. Foreign-currency reserves excluding gold, which stood at $469 billion at the end of January 2022, are more than three times external debt repayment needs for 2022 and cover almost the entire stock of external debt.

Russia's low borrowing needs and large pool of domestic savings will help limit the negative effects of an extension of sovereign debt sanctions to the secondary market, although wide-spread financial sector disruption could impact the functioning of Russia's sovereign debt market. In a severe scenario where all foreign investors are forced to sell their holdings of local- and foreign-currency denominated sovereign debt, pushing up annual funding requirements for the Russian government to around 7% of GDP, Moody's estimates the domestic banking sector to have the capacity to absorb these higher levels of sovereign debt. Furthermore, the central bank has demonstrated its willingness to provide additional liquidity support to the financial sector if needed.

That said, significant new economic and financial sanctions, adding to the persistent sanctions environment which Russia has faced since the annexation of Crimea in 2014, would further weigh on Russia's economic and fiscal strength. Financial sector sanctions could disrupt trade flows and payments for Russia's oil and gas exports which are important for government revenues. New economic sanctions, including controls on access to key imports needed to modernise the economy and support a further diversification in its export mix away from hydrocarbons, or measures targeting Russia's key export sectors such as energy, would weigh on Russia's already low growth potential and generally slow real disposable income growth.

ENVIRONMENTAL, SOCIAL AND GOVERNANCE CONSIDERATIONS

Russia's ESG Credit Impact Score is moderately negative (CIS-3), reflecting high exposure to environmental risks, moderate exposure to social risks, and a moderately negative governance issuer profile score, in part mitigated by financial resilience which is underpinned by the government's very low debt burden and very strong debt affordability.

Moody's assesses Russia's exposure to environmental risks as high (E-4 issuer profile score), reflecting high exposure to carbon transition risk given the important role played by hydrocarbons for exports and government revenue. While global transition towards lower consumption of hydrocarbons will proceed over several decades, Russia is likely to see the impact from a shift in policies in the near term as other countries begin to position their economies to reach their own carbon-neutral targets. Russia also faces moderate risks from the management of waste and pollution which can lead to regional tensions.

Exposure to social risks is moderately negative (S-3 issuer profile score), driven by highly unfavorable demographic trends, which limit Russia's growth potential. A rapidly shrinking population of young workers is likely not only to weigh on the country's aggregate labour input but also reduce the economy's dynamism. Russia also faces moderate social risks from relatively low income growth and uneven access to basic services.

The influence of governance on Russia's credit profile is moderately negative (G-3 issuer profile) and risks are mainly related to weaknesses in the rule of law, property rights and control of corruption, reflected in relatively lower scores on international surveys compared with rating peers. However, the governance profile is supported by credible monetary policy and an effective fiscal rule that limits government spending-induced economic volatility.

GDP per capita (PPP basis, US$): 28,053 (2020 Actual) (also known as Per Capita Income)

Real GDP growth (% change): -2.7% (2020 Actual) (also known as GDP Growth)

Inflation Rate (CPI, % change Dec/Dec): 4.9% (2020 Actual)

Gen. Gov. Financial Balance/GDP: -4% (2020 Actual) (also known as Fiscal Balance)

Current Account Balance/GDP: 2.4% (2020 Actual) (also known as External Balance)

External debt/GDP: 31.4% (2020 Actual)

Economic resiliency: ba1

Default history: At least one default event (on bonds and/or loans) has been recorded since 1983.

On 24 February 2022, a rating committee was called to discuss the rating of Russia, Government of. The main points raised during the discussion were: The issuer's economic fundamentals, including its economic strength, have not materially changed. The issuer's institutions and governance strength have not materially changed. The issuer's fiscal or financial strength, including its debt profile, has not materially changed. The issuer's susceptibility to event risks has materially increased.

FACTORS THAT COULD LEAD TO AN UPGRADE OF RUSSIA'S RATINGS

Given the review for downgrade, an upgrade of Russia's ratings is remote. The ratings could be confirmed with a negative outlook if Moody's concluded with a low likelihood that significant new economic and financial sanctions were to have a very limited impact on Russia's economy, fiscal buffers and financial sector.

FACTORS THAT COULD LEAD TO A DOWNGRADE OF RUSSIA'S RATINGS

Russia's ratings would likely be downgraded if Moody's concluded that new severe and co-ordinated sanctions imposed by Western countries on Russia were likely to result in a sustained disruption to the economy, public finances and financial stability, which could impair the government's ability to service and refinance its debt.

In particular, sanctions which restrict the ability of Russian banks to transact with foreign counterparties, or vice-versa, would result in a scenario where there are challenges to executing cross-border payments in a timely manner, including potentially for sovereign debt payments. In line with Moody's definition, a missed payment on interest or principal, which is not cured within the grace period, would typically be classified as a default and, in such an event, Russia's sovereign rating would likely be downgraded by a number of notches. A B1 sovereign rating would be consistent with the expectation of a full recovery for investors (relative to par plus accrued interest) once the restrictions to timely repayment are lifted or addressed. An expectation of a lower than full recovery could result in a lower rating than B1.

Moody's would consider repositioning Russia's ratings upwards only once any missed payment has been fully cured and Moody's is confident that a similar missed payment event would not reoccur. The default event would imply that the credit profile is unlikely to be consistent with an investment-grade rating.

Furthermore, new severe economic and financial sanctions, or an extensive conflict which has negative spillovers on Russia's economy, materially weighing on Russia's economic and fiscal strength and rapidly eroding its fiscal and external buffers, could result in a downgrade.

The publication of this rating action deviates from the previously scheduled release dates in the UK sovereign calendar published on www.moodys.com. This action was prompted by Russia's further military operation in Ukraine which started on 24 February 2022 and crystallised significant political event risks for the Government of Russia.

MOODY'S PLACES UKRAINE'S B3 RATINGS ON REVIEW FOR DOWNGRADE

Moody's has today placed the Government of Ukraine's B3 foreign- and domestic-currency long-term issuer ratings and foreign-currency senior unsecured rating on review for downgrade.

The decision to place the ratings on review for downgrade was caused by Russia's further military operation in Ukraine. Sizeable external maturities in the coming years and the broader reliance of the economy on foreign-currency funding pose a risk to Ukraine's government liquidity and external position. Material downward credit pressure on Ukraine's ratings would develop unless the disruption was to be short lived and significant external financial support was provided to shore up the country's financing position. While Ukraine benefits from improved fiscal and external buffers, these would likely be insufficient in the event of a prolonged conflict.

The review period will allow Moody's to assess the scale, duration and spillover effects of the conflict on Ukraine's credit profile. Moody's will assess the extent to which the conflict leads to sustained economic and fiscal damage, and the implications for government liquidity and the external position. Moody's will also assess the extent to which Ukraine can secure international financing support and the degree to which this can help to mitigate liquidity pressures. Moody's will look to conclude the review when these credit implications are more evident, particularly as the impact of the conflict becomes clearer in the coming days or weeks.

Ukraine's local- and foreign-currency ceilings remain unchanged at B2. The one-notch gap between the local-currency ceiling and the sovereign rating reflects the low predictability of government and institutions and elevated domestic political and geopolitical risks which create considerable policy uncertainty; external vulnerabilities remain elevated. The foreign-currency ceiling is aligned to the local-currency ceiling, reflecting weak policy effectiveness, already limited capital account openness and elevated external indebtedness with limited foreign exchange reserves.

RATINGS RATIONALE / FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

RATIONALE FOR INITIATING THE REVIEW FOR DOWNGRADE ON UKRAINE'S B3 RATINGS

The conflict poses a material risk to Ukraine's government liquidity and external position given sizeable external maturities in the coming years and the broader reliance of its economy on foreign-currency funding. While Ukraine benefits from improved fiscal and external buffers relative to the 2014-15 crisis, these would likely be insufficient in the event of a prolonged conflict to shore up liquidity risks given reduced funding options, foreign investor outflows and mounting pressure on the external position.

The review period will allow Moody's to assess the extent to which the conflict leads to sustained economic and fiscal damage as well as prolonged disruption to the financial sector. The military escalation will severely affect confidence and economic activity in Ukraine. The spread of the conflict beyond eastern Ukraine to other regions in the country will have more material negative economic consequences given the resulting disruption to the country's industrial and agricultural productive capacity. A higher fiscal deficit and a weaker currency would lead to a substantial increase in the government debt burden from around 55% of GDP at the end of 2021.

Foreign-currency reserves at the end of January 2022 reached their highest level since September 2012, standing at $27.5 billion or around 4 months of import cover according to Moody's definition, although reserves will come under increasing pressure at a time of reduced foreign-currency inflows, particularly as the country's financing options reduce amid heightened borrowing costs and a sustained depreciation of the hryvnia.

The review period will also allow Moody's to assess the extent to which international financial support, through international financial institutions and/or bilateral official assistance, can help to offset liquidity pressures stemming from the government's external refinancing needs of $6.1 billion in 2022 and between $2-6 billion (1-3% of GDP) each year over the next decade. Ukraine was able to access substantial financial support in the wake of the military conflict in 2014-15, including a $17 billion programme with the International Monetary Fund, which gives Moody's confidence that international partners stand ready to provide financial assistance. Some international partners have already announced financing commitments since tensions started mounting, including a €1.2 billion package from the European Union (EU, Aaa stable) and bilateral loans from the United States, the United Kingdom (Aa3 stable), Canada (Aaa stable) and Denmark (Aaa stable).

Moody's expects borrowing costs on international capital markets to remain prohibitive for at least as long as the further conflict lasts. Government bond spreads have spiked above 2,000 basis points, compared to less than 500 basis points at the end of 2020. While the domestic market has been a key source of funding, local banks are unlikely to have the capacity to support the government amid financial sector disruption from the conflict and the risk of significant deposit withdrawals. Banks already hold 75% of outstanding domestic bonds, representing 26% of their total assets.

ENVIRONMENTAL, SOCIAL, GOVERNANCE CONSIDERATIONS

Ukraine's ESG Credit Impact Score is highly negative (CIS-4), reflecting moderately negative exposures to environmental and social risks, and a very weak governance profile. The latter, together with moderate wealth levels, helps to explain Ukraine's relatively low resilience to E and S risks.

Ukraine is moderately exposed to environmental risks. These include physical climate risks, carbon transition and the weak preservation of natural capital, reflected in its low agriculture yields despite its abundance of very fertile black soil, which explains its E-3 issuer profile score. Its exposure to physical climate risk is exacerbated by the importance of the agricultural sector (both in terms of economic contribution and employment), which makes the country's exports vulnerable to climate change and adverse weather events. Ukraine's exposure to carbon transition comes from the fact that transit of gas from Russia to Europe via Ukraine provides a valuable source of foreign-exchange revenue.

Exposure to social risks is moderate (S-3 issuer profile score) and reflects unfavourable demographics and risks related to labour and income, with relatively high youth unemployment, as well as weak health outcomes, and this is despite favourable educational attainment. A persistent demographic drag will likely constrain Ukraine's scope for strengthening its economic competitiveness.

Ukraine has a very highly negative governance profile score (G-5 issuer profile), reflecting weaknesses in the rule of law and widespread corruption, which hinders the business environment and disrupts access to concessional financing, as well as a track record of sovereign defaults.

GDP per capita (PPP basis, US$): 13,129 (2020 Actual) (also known as Per Capita Income)

Real GDP growth (% change): -3.8% (2020 Actual) (also known as GDP Growth)

Inflation Rate (CPI, % change Dec/Dec): 5% (2020 Actual)

Gen. Gov. Financial Balance/GDP: -5.7% (2020 Actual) (also known as Fiscal Balance)

Current Account Balance/GDP: 3.4% (2020 Actual) (also known as External Balance)

External debt/GDP: 80.8% (2020 Actual)

Economic resiliency: b2

Default history: At least one default event (on bonds and/or loans) has been recorded since 1983.

On 24 February 2022, a rating committee was called to discuss the rating of Ukraine, Government of. The main points raised during the discussion were: The issuer's economic fundamentals, including its economic strength, have not materially changed. The issuer's institutions and governance strength have not materially changed. The issuer's fiscal or financial strength, including its debt profile, has not materially changed. The issuer's susceptibility to event risks has materially increased.

FACTORS THAT COULD LEAD TO AN UPGRADE OF UKRAINE'S RATINGS

Given the review for downgrade, an upgrade of Ukraine's ratings is remote.

Ukraine's B3 ratings would likely be confirmed at their current level with a negative outlook if disruption arising from the conflict was to be short-lived, resulting in only limited economic and financial disruption and significant external financial support was provided to shore up the country's financing position.

FACTORS THAT COULD LEAD TO A DOWNGRADE OF UKRAINE'S RATINGS

Ukraine's ratings could be downgraded if Ukraine's ability to refinance its large external debt maturities was impaired as a result of a prolonged conflict. Such a scenario would likely entail a significant degree of uncertainty around the extent to which the international community's financial support can mitigate liquidity risks. Furthermore, a reduction in the capacity of Ukraine to repay its obligations as a result of significant economic and fiscal damage arising from the conflict could lead to a downgrade.

The publication of this rating action deviates from the previously scheduled release dates in the UK sovereign calendar published on www.moodys.com. This action was prompted by Russia's further military operation in Ukraine which started on 24 February 2022 and crystallised significant political event risks for the Government of Ukraine.

The principal methodology used in these ratings was Sovereign Ratings Methodology published in November 2019 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1158631. Alternatively, please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.

The weighting of all rating factors is described in the methodology used in this credit rating action, if applicable.

REGULATORY DISCLOSURES

The List of Affected Credit Ratings announced here are a mix of solicited and unsolicited credit ratings. For additional information, please refer to Moody's Policy for Designating and Assigning Unsolicited Credit Ratings available on its website www.moodys.com. Additionally, the List of Affected Credit Ratings includes additional disclosures that vary with regard to some of the ratings. Please click on this link https://www.moodys.com/viewresearchdoc.aspx?docid=PBC_ARFTL463212 for the List of Affected Credit Ratings. This list is an integral part of this Press Release and provides, for each of the credit ratings covered, Moody's disclosures on the following items:

• EU Endorsement Status

• UK Endorsement Status

• Rating Solicitation

• Issuer Participation

• Participation: Access to Management

• Participation: Access to Internal Documents

• Releasing Office

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody's Rating Symbols and Definitions can be found at: https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_79004.

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

For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit rating action, the associated regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.

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

Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.

Moody's general principles for assessing environmental, social and governance (ESG) risks in our credit analysis can be found at http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1288235.

Items color coded in purple in this Press Release relate to unsolicited ratings for a rated entity which is non-participating.

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.

Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosures for each credit rating.

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

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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