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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.

 

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Related Issuers
Asset Backed Funding Corporation NIM Trust 2001-AQ1 Notes
Bear Stearns Structured Products Inc. NIM Trust 2004-10
Bear Stearns Structured Products Inc. NIM Trust 2007-N1
Bear Stearns Structured Products Inc. NIM Trust 2007-N7 Notes, Series 2007-N7-II
Bear Stearns Structured Products Inc. NIM Trust 2007-N7-IV
BSSP NIM Trust 2004-QA1
BSSP NIM Trust 2007-N2 Notes, Series 2007-N2-VIII
BSSP NIM Trust 2007-N2 Notes, Series 2007-N2-X
BSSP NIM Trust 2007-N3 Notes, Series 2007-N3-IV
BSSP NIM Trust 2007-N3 Notes, Series 2007-N3-V
FFML Net Interest Margin Trust 2003-FFB
GSAA Home Equity Trust 2005-NIM6
GSMSC Net Interest Margin Securities, Series 2007-NIM1
Lehman XS Net Interest Margin Notes Series 2005-1
Lehman XS Net Interest Margin Notes Series 2005-10
Lehman XS Net Interest Margin Notes Series 2005-2
Lehman XS Net Interest Margin Notes Series 2005-6
Lehman XS Net Interest Margin Notes Series 2005-8
Lehman XS Net Interest Margin Notes Series 2006-3
Lehman XS Net Interest Margin Notes Series 2006-7
Lehman XS Net Interest Margin Notes Series 2006-GP1
Lehman XS Net Interest Margin Notes Series 2006-GP3
Lehman XS Net Interest Margin Notes Series 2006-GPM4
Lehman XS Net Interest Margin Notes Series 2006-GPM5
Lehman XS Net Interest Margin Notes Series 2006-GPM6
Lehman XS Net Interest Margin Notes Series 2006-GPM7
Lehman XS Net Interest Margin Notes Series 2006-GPM8
Lehman XS Net Interest Margin Notes Series 2007-GPM1-1
Lehman XS Net Interest Margin Notes Series 2007-QO8
Lehman XS NIM 1 Company 2005-7N
Lehman XS Nim 1 Company 2007-GPM2
Lehman XS NIM Company 2005-5N
Lehman XS NIM Company 2005-9N
Lehman XS NIM Company 2006-AR2
Lehman XS NIM Company 2006-AR4
Lehman XS NIM Company 2006-GP2
Lehman XS NIM Company 2006-GP4
Long Beach Asset Holdings Corp. CI 2006-WL2 NIM Notes, Series 2006-WL2
MASTR Alternative Loan NIM 2006-1
MASTR Alternative Loan NIM 2006-3
MASTR Alternative Loan NIM 2006-4
MASTR Alternative Loan NIM 2006-5
MASTR CI-CW1 NIM
SAIL Net Interest Margin Notes, Series 2003-3
SAIL Net Interest Margin Notes, Series 2003-5
SARM Net Interest Margin Notes, Series 2005-10
SARM Net Interest Margin Notes, Series 2005-16XS
SARM Net Interest Margin Notes, Series 2005-19XS-1
SARM Net Interest Margin Notes, Series 2005-19XS-2
SASCO ARC Net Interest Margin Notes, Series 2003-BC2
SASCO Net Interest Margin Trust 2003-12XS
SASCO Net Interest Margin Trust 2003-36XS
Sharps SP I LLC Net Interest Margin 2006-AHM3N
Sharps SP I LLC Net Interest Margin Trust 2003-2XSN
Sharps SP I LLC Net Interest Margin Trust 2004-5N
Sharps SP I LLC Net Interest Margin Trust 2006-AF1N
Wachovia Amortization Controlled HELOC NIM Trust 2006-N1
Rating Action:

Moody's reviews ratings of RMBS net interest margin securities

15 Apr 2009

New York, April 15, 2009 -- Moody's Investors Service has placed the ratings of 76 net interest margin (NIM) securities backed by residential mortgage-backed securitizations (RMBS) on review for possible downgrade. These NIM transactions rely on residual cash flows and prepayment penalties generated by the underlying mortgage-backed securitizations. These cash flows are sensitive to a number of factors:

i) Prepayment speeds on the collateral backing the RMBS

ii) Magnitude and timing of losses incurred on the collateral backing the underlying RMBS

iii) Impact of trigger breaches (which in turn affects step-down and release of cash to residual bondholders) and

iv) Volume and magnitude of interest rate modifications (which affects excess spread).

These securities have been placed on review based on the poor performance on the underlying transactions that has negatively impacted residual payments to the NIM holders.

Moody's analysis of NIM transactions with respect to this review primarily focuses on each transaction's recent average monthly principal paydown rate. As delinquency and losses have accumulated in the transactions underlying the NIM, residual cash flows have severely declined and, in most cases, disappeared. As a result, the large majority of these transactions have not received principal payments in recent months and many have accrued unpaid interest. Projected future loss levels on the large majority of underlying transactions are now higher than previously estimated. These elevated loss levels further reduce the likelihood that the net interest margin securities will ultimately be paid in full.

During the review period, Moody's will analyze the likelihood of NIM repayment by reviewing potential sources of cash in relation to outstanding liabilities. The potential sources of cash to the NIM include i) excess spread net of projected future losses, ii) excess overcollateralization in the event of a step-down and iii) collections of prepayment penalties. To the extent the NIM has accrued unpaid interest obligations that must be paid prior to retiring the outstanding principal, such amounts will also be taken into account when evaluating the expected severity of loss to the NIM bondholders. It is expected that nearly all of the bonds placed under review would be downgraded to B1 or below. Additionally, to the extent that subordinate bonds of the underlying transactions have incurred principal impairments or have been downgraded to Ca or C, it is expected that the associated NIM security would be similarly downgraded to Ca or C. Final rating actions resolving these reviews are expected in the next 3 to 4 weeks.

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

Asset Backed Funding Corporation NIM Trust 2001-AQ1 Notes

Cl. A, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Bear Stearns Structured Products Inc. NIM Trust 2004-10

Notes, B2 Placed Under Review for Possible Downgrade; previously on 2/16/2005 Assigned B2

BSSP NIM Trust 2004-QA1

Notes, Caa2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa2

Bear Stearns Structured Products Inc. NIM Trust 2007-N1

Cl. I-A-1, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

BSSP NIM Trust 2007-N2 Notes, Series 2007-N2-VIII

Cl. VIII-A-1, Caa1 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa1

BSSP NIM Trust 2007-N2 Notes, Series 2007-N2-X

Cl. X-A-2, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

BSSP NIM Trust 2007-N3 Notes, Series 2007-N3-IV

Cl. IV-A-1, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Cl. IV-A-2, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

BSSP NIM Trust 2007-N3 Notes, Series 2007-N3-V

Cl. V-A-1, Caa2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa2

Bear Stearns Structured Products Inc. NIM Trust 2007-N7 Notes, Series 2007-N7-II

Cl. II-A-3, Ba2 Placed Under Review for Possible Downgrade; previously on 10/18/2007 Assigned Ba2

Bear Stearns Structured Products Inc. NIM Trust 2007-N7-IV

Cl. IV-A-3, Ba2 Placed Under Review for Possible Downgrade; previously on 9/20/2007 Assigned Ba2

FFML Net Interest Margin Trust 2003-FFB

Cl. A Notes, B3 Placed Under Review for Possible Downgrade; previously on 4/20/2007 Downgraded to B3

GSAA Home Equity Trust 2005-NIM6

Notes, B1 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B1

GSMSC Net Interest Margin Securities, Series 2007-NIM1

Cl. N2, Baa3 Placed Under Review for Possible Downgrade; previously on 2/9/2007 Assigned Baa3

Cl. N3, Ba3 Placed Under Review for Possible Downgrade; previously on 2/9/2007 Assigned Ba3

Cl. N4, B3 Placed Under Review for Possible Downgrade; previously on 2/9/2007 Assigned B3

Lehman XS NIM 1 Company 2005-7N

Cl. A-2, Baa3 Placed Under Review for Possible Downgrade; previously on 2/1/2006 Assigned Baa3

Lehman XS Net Interest Margin Notes Series 2007-GPM1-1

Cl. A-2, Baa3 Placed Under Review for Possible Downgrade; previously on 3/26/2007 Assigned Baa3

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 3/26/2007 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 3/26/2007 Assigned B2

Lehman XS Nim 1 Company 2007-GPM2

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 5/29/2007 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 5/29/2007 Assigned B2

Lehman XS Net Interest Margin Notes Series 2005-1

Cl. A, B2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B2

Cl. B, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Lehman XS Net Interest Margin Notes Series 2005-10

Cl. A, A3 Placed Under Review for Possible Downgrade; previously on 2/10/2006 Assigned A3

Cl. B, B3 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B3

Lehman XS Net Interest Margin Notes Series 2005-2

Cl. A, Caa1 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa1

Cl. B, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Lehman XS NIM Company 2005-5N

Cl. B, Baa3 Placed Under Review for Possible Downgrade; previously on 12/16/2005 Assigned Baa3

Lehman XS Net Interest Margin Notes Series 2005-6

Cl. A, B2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B2

Lehman XS Net Interest Margin Notes Series 2005-8

Cl. B, Caa3 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa3

Lehman XS Net Interest Margin Notes Series 2006-3

Cl. A, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Cl. B, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Lehman XS Net Interest Margin Notes Series 2006-7

Cl. A, Caa2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa2

Cl. B, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

Lehman XS NIM Company 2006-AR2

Cl. A-1, A3 Placed Under Review for Possible Downgrade; previously on 5/24/2006 Assigned A3

Lehman XS NIM Company 2006-AR4

Cl. A-4, Caa2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa2

Lehman XS Net Interest Margin Notes Series 2006-GP1

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 6/29/2006 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 6/29/2006 Assigned B2

Lehman XS NIM Company 2006-GP2

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 8/2/2006 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 8/2/2006 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GP3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 8/2/2006 Assigned B2

Lehman XS NIM Company 2006-GP4

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 8/22/2006 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 8/22/2006 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GPM4

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 9/26/2006 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 9/26/2006 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GPM5

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 10/27/2006 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GPM6

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 12/1/2006 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GPM7

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 1/8/2007 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 1/8/2007 Assigned B2

Lehman XS Net Interest Margin Notes Series 2006-GPM8

Cl. A-3, Ba3 Placed Under Review for Possible Downgrade; previously on 1/25/2007 Assigned Ba3

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 1/25/2007 Assigned B2

Lehman XS Net Interest Margin Notes Series 2007-QO8

Cl. A-4, B2 Placed Under Review for Possible Downgrade; previously on 3/16/2007 Assigned B2

Lehman XS NIM Company 2005-9N

Cl. A-2, Baa3 Placed Under Review for Possible Downgrade; previously on 3/6/2006 Assigned Baa3

Long Beach Asset Holdings Corp. CI 2006-WL2 NIM Notes, Series 2006-WL2

Cl. N-2, A3 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to A3

MASTR Alternative Loan NIM 2006-1

Cl. N-1, Baa2 Placed Under Review for Possible Downgrade; previously on 1/27/2006 Assigned Baa2

MASTR Alternative Loan NIM 2006-3

Cl. N-3, Caa1 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa1

MASTR Alternative Loan NIM 2006-4

Cl. N-2, B3 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to B3

Cl. N-3, Caa1 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa1

MASTR Alternative Loan NIM 2006-5

Cl. N-3, Caa1 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa1

MASTR CI-CW1 NIM

Cl. N-1, Ba2 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Ba2

Cl. N-2, Caa1 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa1

SAIL Net Interest Margin Notes, Series 2003-3

Cl. A Notes, Caa2 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa2

SAIL Net Interest Margin Notes, Series 2003-5

Cl. A Notes, Caa2 Placed Under Review for Possible Downgrade; previously on 7/2/2008 Downgraded to Caa2

SARM Net Interest Margin Notes, Series 2005-19XS-1

Cl. A-2, Baa3 Placed Under Review for Possible Downgrade; previously on 11/21/2005 Assigned Baa3

SARM Net Interest Margin Notes, Series 2005-19XS-2

Cl. A-2, Baa3 Placed Under Review for Possible Downgrade; previously on 11/21/2005 Assigned Baa3

SARM Net Interest Margin Notes, Series 2005-16XS

Cl. A, B2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B2

SARM Net Interest Margin Notes, Series 2005-10

Cl. A, Ca Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Ca

SASCO Net Interest Margin Trust 2003-12XS

Cl. A, Caa3 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa3

SASCO Net Interest Margin Trust 2003-36XS

Cl. A, B2 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to B2

SASCO ARC Net Interest Margin Notes, Series 2003-BC2

Cl. N2, Caa3 Placed Under Review for Possible Downgrade; previously on 7/1/2008 Downgraded to Caa3

Sharps SP I LLC Net Interest Margin Trust 2003-2XSN

Notes, Baa2 Placed Under Review for Possible Downgrade; previously on 12/24/2003 Assigned Baa2

Sharps SP I LLC Net Interest Margin 2006-AHM3N

Cl. N-3, Ba2 Placed Under Review for Possible Downgrade; previously on 10/9/2006 Assigned Ba2

Sharps SP I LLC Net Interest Margin Trust 2004-5N

Notes, Baa3 Placed Under Review for Possible Downgrade; previously on 10/27/2004 Assigned Baa3

Sharps SP I LLC Net Interest Margin Trust 2006-AF1N

Notes, Baa3 Placed Under Review for Possible Downgrade; previously on 6/9/2006 Assigned Baa3

Wachovia Amortization Controlled HELOC NIM Trust 2006-N1

Notes, A3 Placed Under Review for Possible Downgrade; previously on 1/4/2007 Assigned A3

For mor informations see www.Moodys.com

New York
Debashish Chatterjee
VP - Senior Credit Officer
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

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

Moody's reviews ratings of RMBS net interest margin securities
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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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 $2,700,000. 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."

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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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