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Rating Action:

Moody's takes action on $2 Billion of Subprime RMBS Issued by Various Trusts

26 Feb 2013

New York, February 26, 2013 -- Moody's Investors Service has downgraded the rating of 16 tranches, upgraded the rating of 13 tranches, affirmed the rating of 99 tranches, and confirmed the rating of 1 tranche from 13 transactions, backed by Subprime mortgage loans.

Complete rating actions are as follows:

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2005-HE4

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Upgraded to Ba1 (sf); previously on May 30, 2012 Ba2 (sf) Placed Under Review for Possible Upgrade

Cl. M-3, Upgraded to B1 (sf); previously on May 30, 2012 Caa2 (sf) Placed Under Review for Possible Upgrade

Cl. M-4, Upgraded to Ca (sf); previously on May 30, 2012 C (sf) Placed Under Review for Possible Upgrade

Cl. M-5, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2005-HE5

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Upgraded to Ba2 (sf); previously on Aug 2, 2012 Confirmed at Ba3 (sf)

Cl. M-3, Affirmed Caa2 (sf); previously on Aug 2, 2012 Upgraded to Caa2 (sf)

Cl. M-4, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Oct 15, 2008 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Oct 15, 2008 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Oct 15, 2008 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Oct 15, 2008 Downgraded to C (sf)

Cl. B-1, Affirmed C (sf); previously on Oct 15, 2008 Downgraded to C (sf)

Issuer: Ameriquest Mortgage Securities Inc., Series 2005-R2

Cl. A-1B, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. A-2B, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Affirmed Baa1 (sf); previously on Apr 14, 2010 Downgraded to Baa1 (sf)

Cl. M-3, Upgraded to Ba2 (sf); previously on Aug 21, 2012 Confirmed at B1 (sf)

Cl. M-4, Affirmed Caa3 (sf); previously on Apr 14, 2010 Downgraded to Caa3 (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Issuer: Ameriquest Mortgage Securities Inc., Series 2005-R3

Cl. A-1A, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. A-1B, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. A-2A, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. A-2B, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. A-3D, Affirmed Aaa (sf); previously on Apr 14, 2010 Confirmed at Aaa (sf)

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Affirmed A3 (sf); previously on Apr 14, 2010 Downgraded to A3 (sf)

Cl. M-3, Affirmed Ba1 (sf); previously on Apr 14, 2010 Downgraded to Ba1 (sf)

Cl. M-4, Affirmed Caa1 (sf); previously on Apr 14, 2010 Downgraded to Caa1 (sf)

Cl. M-5, Affirmed Caa3 (sf); previously on Apr 14, 2010 Downgraded to Caa3 (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 14, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Nov 17, 2008 Downgraded to C (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust 2005-HE6

Cl. M1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M2, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa3 (sf) Placed Under Review for Possible Downgrade

Cl. M4, Upgraded to Ba3 (sf); previously on Jul 12, 2010 Downgraded to B2 (sf)

Cl. M3, Affirmed Baa1 (sf); previously on Jul 12, 2010 Downgraded to Baa1 (sf)

Cl. M5, Affirmed Caa2 (sf); previously on Jul 12, 2010 Downgraded to Caa2 (sf)

Cl. M6, Affirmed C (sf); previously on Jul 12, 2010 Downgraded to C (sf)

Cl. M7, Affirmed C (sf); previously on Jul 12, 2010 Downgraded to C (sf)

Cl. M8, Affirmed C (sf); previously on Jul 12, 2010 Downgraded to C (sf)

Cl. M9, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M10, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2005-NC1

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Affirmed Ba1 (sf); previously on Apr 29, 2010 Downgraded to Ba1 (sf)

Cl. M-3, Affirmed Caa2 (sf); previously on Apr 29, 2010 Downgraded to Caa2 (sf)

Cl. M-4, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to C (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-OPT3

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Affirmed Baa2 (sf); previously on Jul 18, 2011 Downgraded to Baa2 (sf)

Cl. M-3, Affirmed B3 (sf); previously on Jul 18, 2011 Downgraded to B3 (sf)

Cl. M-4, Affirmed Ca (sf); previously on Jul 18, 2011 Downgraded to Ca (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 19, 2009 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Mar 19, 2009 Downgraded to C (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-OPT4

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to A3 (sf); previously on Jan 10, 2013 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Upgraded to Ba1 (sf); previously on Sep 4, 2012 Upgraded to Ba2 (sf)

Cl. M-4, Affirmed Caa1 (sf); previously on Sep 4, 2012 Upgraded to Caa1 (sf)

Cl. M-5, Affirmed Ca (sf); previously on Sep 4, 2012 Upgraded to Ca (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Mar 19, 2009 Downgraded to C (sf)

Cl. M-11, Affirmed C (sf); previously on Mar 19, 2009 Downgraded to C (sf)

Issuer: Equifirst Mortgage Loan Trust 2005-1

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to A3 (sf); previously on Jan 10, 2013 A2 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Affirmed Ba2 (sf); previously on Jul 18, 2011 Downgraded to Ba2 (sf)

Cl. M-4, Affirmed Caa1 (sf); previously on Sep 14, 2012 Confirmed at Caa1 (sf)

Cl. M-5, Affirmed Ca (sf); previously on Sep 14, 2012 Confirmed at Ca (sf)

Cl. M-6, Affirmed Ca (sf); previously on Sep 14, 2012 Confirmed at Ca (sf)

Cl. M-7, Affirmed C (sf); previously on Jul 18, 2011 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Cl. B-1, Affirmed C (sf); previously on Mar 13, 2009 Downgraded to C (sf)

Issuer: Fremont Home Loan Trust 2005-2

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Upgraded to Baa2 (sf); previously on Apr 29, 2010 Downgraded to Ba3 (sf)

Cl. M-3, Affirmed Ca (sf); previously on Apr 29, 2010 Downgraded to Ca (sf)

Cl. M-4, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 29, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Mar 17, 2009 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Mar 17, 2009 Downgraded to C (sf)

Issuer: IndyMac Home Equity Mortgage Loan Asset-Backed Trust, INABS 2005-A

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa3 (sf) Placed Under Review for Possible Downgrade

Cl. M-3, Affirmed Baa1 (sf); previously on Sep 15, 2010 Upgraded to Baa1 (sf)

Cl. M-4, Affirmed Ba3 (sf); previously on Sep 5, 2012 Confirmed at Ba3 (sf)

Cl. M-5, Affirmed Caa2 (sf); previously on Sep 15, 2010 Downgraded to Caa2 (sf)

Cl. M-6, Affirmed C (sf); previously on Sep 15, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Sep 15, 2010 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 17, 2009 Downgraded to C (sf)

Cl. M-9, Affirmed C (sf); previously on Mar 17, 2009 Downgraded to C (sf)

Cl. M-10, Affirmed C (sf); previously on Mar 17, 2009 Downgraded to C (sf)

Issuer: Long Beach Mortgage Loan Trust 2005-1

Cl. M-1, Downgraded to A3 (sf); previously on Jan 10, 2013 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. M-2, Upgraded to Baa3 (sf); previously on Sep 14, 2012 Upgraded to Ba2 (sf)

Cl. M-3, Upgraded to Caa2 (sf); previously on Sep 14, 2012 Upgraded to Ca (sf)

Cl. M-4, Affirmed C (sf); previously on Apr 30, 2010 Downgraded to C (sf)

Cl. M-5, Affirmed C (sf); previously on Apr 30, 2010 Downgraded to C (sf)

Cl. M-6, Affirmed C (sf); previously on Apr 30, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to C (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-HE1

Cl. M-3, Upgraded to Ba1 (sf); previously on May 30, 2012 B2 (sf) Placed Under Review for Possible Upgrade

Cl. M-4, Upgraded to B2 (sf); previously on May 30, 2012 Caa3 (sf) Placed Under Review for Possible Upgrade

Cl. M-5, Upgraded to Ca (sf); previously on May 30, 2012 C (sf) Placed Under Review for Possible Upgrade

Cl. M-2, Confirmed at A3 (sf); previously on May 30, 2012 A3 (sf) Placed Under Review for Possible Upgrade

Cl. M-6, Affirmed C (sf); previously on May 5, 2010 Downgraded to C (sf)

Cl. M-7, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to C (sf)

Cl. M-8, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to C (sf)

RATINGS RATIONALE

The actions are a result of recent performance reviews of these transactions and reflect Moody's updated loss expectations on these pools.

Today's rating actions constitute of a number of downgrades, upgrades, affirmations and a confirmation. The downgrades are primarily due to the tranches' weak interest shortfall reimbursement mechanisms.

The tranches downgraded to A3 do not have interest shortfalls but in the event of an interest shortfall, structural limitations in the transactions will prevent recoupment of interest shortfalls even if funds are available in subsequent periods. Missed interest payments on these tranches can typically only be made up from excess interest after the overcollateralization is built to a target amount. In these transactions since overcollateralization is already below target due to poor performance, any future missed interest payments to these tranches are unlikely to be paid. Moody's caps the ratings of such tranches with weak interest shortfall reimbursement at A3 as long as they have not experienced any shortfall.

Ratings on tranches that currently have very small unrecoverable interest shortfalls are capped at Baa3. For tranches with larger outstanding interest shortfalls, Moody's applies "Moody's Approach to Rating Structured Finance Securities in Default" published in November 2009. These rating action take into account only credit-related interest shortfall risks.

The methodologies used in these ratings were "Moody's Approach to Rating US Residential Mortgage-Backed Securities" published in December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology" published in July 2011. Please see the Credit Policy page on www.moodys.com for a copy of these methodologies.

Moody's adjusts the methodologies noted above for Moody's current view on loan modifications. As a result of an extension of the Home Affordable Modification Program (HAMP) to 2013 and an increased use of private modifications, Moody's is extending its previous view that loan modifications will only occur through the end of 2012. It is now assuming that the loan modifications will continue at current levels until the end of 2013.

Other factors used in these ratings are described in "Moody's Approach to Rating Structured Finance Securities in Default" published in November 2009.

When assigning the final ratings to senior bonds, in addition to the methodologies described above, we considered the volatility of the projected losses and timeline of the expected defaults. For bonds backed by small pools, we also considered the current pipeline composition as well as any specific loss allocation rules that could preserve or deplete the overcollateralization available for the senior bonds at different pace. The above methodology only applies to pools with at least 40 loans and a pool factor of greater than 5%. Moody's may withdraw its rating when the pool factor drops below 5% and the number of loans in the pool declines to 40 loans or lower unless specific structural features allow for a monitoring of the transaction (such as a credit enhancement floor).

The primary sources of assumption uncertainty are our central macroeconomic forecast and performance volatility as a result of servicer-related activity such as modifications. The unemployment rate fell from 8.5% in December 2011 to 7.9% in January 2013. Moody's forecasts a unemployment central range of 7.0% to 8.0% for the 2013 year. Moody's expects housing prices to continue to rise in 2013. Performance of RMBS continues to remain highly dependent on servicer activity such as modification-related principal forgiveness and interest rate reductions. Any change resulting from servicing transfers or other policy or regulatory change can also impact the performance of these transactions.

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

Excel: http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF317828

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

Excel: http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_SF198689

REGULATORY DISCLOSURES

Moody's received and took into account one or more third party assessments on the due diligence performed regarding the underlying assets or financial instruments in these transactions and the assessments had a neutral impact on the rating.

In conducting surveillance of these credits, Moody's considered performance data contained in servicer and remittance reports. Moody's obtains servicer reports on these transactions on a periodic basis, at least annually.

For ratings issued on a program, series or category/class of debt, this announcement provides certain 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 certain 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 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 rating action, and whose ratings may change as a result of this 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.

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.

Mark Branton
Asst Vice President - Analyst
Structured Finance Group
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Amita Shrivastava
VP - Senior Credit Officer
Structured Finance Group
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

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

Moody's takes action on $2 Billion of Subprime RMBS Issued by Various Trusts
No Related Data.
© 2021 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 JPY125,000 to approximately JPY550,000,000.

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

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