info

Yes No
Moodys.com
Terms of Use
REGULATORY AFFAIRS
CAREERS
.
ABOUT US
.
CONTACT US
HOME
Please Note
We brought you to this page based on your search query. If this isn't what you are looking for, you can continue to Search Results for ""
The maximum number of items you can export is 3,000. Please reduce your list by using the filtering tool to the left.
Close
Close
Email Research
Recipient email addresses will not be used in mailing lists or redistributed.
Recipient's
Email

Use semicolon to separate each address, limit to 20 addresses.
Enter the
characters you see
Can't read?
Try a new set
Send Cancel
Close
Email Research
Thank you for your interest in sharing Moody's Research. You have reached the daily limit of Research email sharings.
OK
Close
Thank you!
You have successfully sent the research.
Please note: some research requires a paid subscription in order to access.
OK
Already a customer?
LOG IN
Don't want to see this again?
REGISTER
OR
Accept our Terms of Use to continue to Moodys.com:

PLEASE READ AND SCROLL DOWN!

 

By clicking “I AGREE” [at the end of this document], you indicate that you understand and intend these terms and conditions to be the legal equivalent of a signed, written contract and equally binding, and that you accept such terms and conditions as a condition of viewing any and all Moody’s inform​ation that becomes accessible to you [after clicking “I AGREE”] (the “Information”).   References herein to “Moody’s” include Moody’s Corporation, Inc. and each of its subsidiaries and affiliates.

 

Terms of One-Time Website Use

 

1.            Unless you have entered into an express written contract with Moody’s to the contrary, you agree that you have no right to use the Information in a commercial or public setting and no right to copy it, save it, print it, sell it, or publish or distribute any portion of it in any form.               

 

2.            You acknowledge and agree that Moody’s credit ratings: (i) are current opinions of the future relative creditworthiness of securities and address no other risk; and (ii) are not statements of current or historical fact or recommendations to purchase, hold or sell particular securities.  Moody’s credit ratings and publications are not intended for retail investors, and it would be reckless and inappropriate for retail investors to use Moody’s credit ratings and publications when making an investment decision.  No warranty, express or implied, as the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of any Moody’s credit rating is given or made by Moody’s in any form whatsoever.          

 

3.            To the extent permitted by law, Moody’s and its directors, officers, employees, representatives, licensors and suppliers disclaim liability for: (i) any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with use of the Information; and (ii) any direct or compensatory damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud or any other type of liability that by law cannot be excluded) on the part of Moody’s or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with use of the Information.

 

4.            You agree to read [and be bound by] the more detailed disclosures regarding Moody’s ratings and the limitations of Moody’s liability included in the Information.     

 

5.            You agree that any disputes relating to this agreement or your use of the Information, whether sounding in contract, tort, statute or otherwise, shall be governed by the laws of the State of New York and shall be subject to the exclusive jurisdiction of the courts of the State of New York located in the City and County of New York, Borough of Manhattan.​​​

I AGREE
Rating Action:

Moody's takes action on certain Deutsche Bank Alt-A deals

05 Jan 2009
Moody's takes action on certain Deutsche Bank Alt-A deals

New York, January 05, 2009 -- Moody's Investors Service has downgraded the ratings of 70 tranches from 10 Alt-A RMBS transactions issued by Deutsche Alt-A Securities Inc and Deutsche Mortgage Securities Inc and withdrew the ratings of 2 interest-only tranches upon legal expiration. The collateral backing these transactions consists primarily of first-lien, fixed and adjustable-rate, Alt-A residential mortgage loans.

These actions are a result of updated loss expectations on the underlying collateral relative to available credit enhancement.

Moody's methodology for rating securities for more seasoned Alt-A pools i.e. prior to 2H 2005 averages the annualized loss rate from last 12 months ("Recent Losses") and the projected loss rate over the next 12 months ("Pipeline Losses"), and then translates these measures into lifetime losses based on a deal's expected remaining life. Recent Losses are calculated by assessing cumulative losses incurred over the past 12-months as a percentage of the average pool factor in the last year. For Pipeline Losses, Moody's uses an annualized roll rate of 15%, 30%, 65% and 90% for loans that are delinquent 60-days, 90+ days, are in foreclosure, and REO respectively. Moody's then applies deal-specific severity assumptions ranging from 40% to 55%. The results of these two calculations - Recent Losses and Pipeline Losses - are weighted to arrive at the lifetime cumulative loss projection.

Once expected losses have been assigned to each collateral group, Moody's assesses available credit enhancement from subordination, overcollateralization, excess spread and any external support (mortgage insurance, pool policy, etc.). The available enhancement is analyzed against projected future losses to ultimately arrive at an updated rating.

For securities insured by a financial guarantor, the rating on the securities is equal to the higher of (i) the guarantor's financial strength rating and (ii) the current underlying rating (i.e., absent consideration of the guaranty) on the security. The principal methodology used in determining the underlying rating is the same methodology for rating securities that do not have a financial guaranty and is as described in the two previous paragraphs.

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 and Methodologies directory.

List of actions

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series 2003-2XS

Cl. A-5, Downgraded to Aa1, previously on 11/20/2003 Assigned Aaa

Cl. A-IO, Withdrawn, previously on 11/20/2003 Assigned Aaa

Cl. M-1, Downgraded to A2, previously on 11/20/2003 Assigned Aa2

Cl. M-2, Downgraded to Ba3, previously on 11/20/2003 Assigned A2

Cl. M-3, Downgraded to Ca, previously on 11/20/2003 Assigned Baa2

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series 2003-4XS

Cl. A-5, Downgraded to Aa2, previously on 12/24/2003 Assigned Aaa

Cl. A-6A, Downgraded to Aa3, previously on 1/17/2008 confirmed at Aaa

Financial Guarantor: MBIA Insurance Corporation (Baa1)

Underlying Rating: Downgraded to Aa3, previously on 9/16/2008 published Aaa

Cl. A-6B, Downgraded to Aa3, previously on 12/24/2003 Assigned Aaa

Cl. M-1, Downgraded to Baa1, previously on 12/24/2003 Assigned Aa2

Cl. M-2, Downgraded to B3, previously on 10/30/2006 Downgraded to Baa1

Cl. M-3, Downgraded to Ca, previously on 10/30/2006 Downgraded to Ba2

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series 2005-1

Cl. I-A-4, Downgraded to Aa1, previously on 3/30/2005 Assigned Aaa

Cl. M, Downgraded to A3, previously on 3/30/2005 Assigned Aa2

Cl. B-1, Downgraded to Ba2, previously on 3/30/2005 Assigned A2

Cl. B-2, Downgraded to Caa2, previously on 3/30/2005 Assigned Baa2

Cl. B-3, Downgraded to Ca, previously on 3/30/2005 Assigned Ba2

Cl. B-4, Downgraded to Ca, previously on 3/30/2005 Assigned B2

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series 2005-2

Cl. I-A-1, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-2, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-3, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-4, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-5, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-6, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. I-A-7, Downgraded to Aa3, previously on 4/19/2005 Assigned Aaa

Cl. II-A-1, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. II-A-2, Downgraded to Aa2, previously on 4/19/2005 Assigned Aaa

Cl. II-A-3, Downgraded to Aa3, previously on 4/19/2005 Assigned Aaa

Cl. M, Downgraded to Baa2, previously on 4/19/2005 Assigned Aa2

Cl. B-1, Downgraded to B1, previously on 4/19/2005 Assigned A2

Cl. B-2, Downgraded to Ca, previously on 4/19/2005 Assigned Baa2

Cl. B-3, Downgraded to Ca, previously on 4/19/2005 Assigned Ba2

Cl. B-4, Downgraded to Ca, previously on 4/19/2005 Assigned B2

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series 2005-3

Cl. I-A-1, Downgraded to Aa1, previously on 6/16/2005 Assigned Aaa

Cl. IV-A-7, Downgraded to Aa1, previously on 6/16/2005 Assigned Aaa

Cl. V-A-1, Downgraded to Aa2, previously on 6/16/2005 Assigned Aaa

Cl. V-A-2, Downgraded to Aa2, previously on 6/16/2005 Assigned Aaa

Cl. V-A-3, Downgraded to Aa2, previously on 6/16/2005 Assigned Aaa

Cl. M, Downgraded to Baa1, previously on 6/16/2005 Assigned Aa2

Cl. B-1, Downgraded to Ba3, previously on 6/16/2005 Assigned A2

Cl. B-2, Downgraded to Ca, previously on 6/16/2005 Assigned Baa2

Cl. B-3, Downgraded to Ca, previously on 6/16/2005 Assigned Ba2

Cl. B-4, Downgraded to Ca, previously on 6/16/2005 Assigned B2

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Loan Trust, Series 2004-1

Cl. III-M-1, Downgraded to Aa3, previously on 2/26/2004 Assigned Aa2

Cl. III-M-2, Downgraded to A3, previously on 2/26/2004 Assigned A2

Cl. III-M-3, Downgraded to Baa3, previously on 2/26/2004 Assigned Baa1

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Loan Trust, Series 2004-2

Cl. M-1, Downgraded to A1, previously on 3/30/2004 Assigned Aa2

Cl. M-2, Downgraded to Baa1, previously on 3/30/2004 Assigned A2

Cl. M-3, Downgraded to Ba2, previously on 3/30/2004 Assigned Baa1

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Loan Trust, Series 2004-3

Cl. I-A-5, Downgraded to Aa1, previously on 1/16/2008 confirmed at Aaa

Financial Guarantor: Ambac Assurance Corporation (Baa1)

Underlying Rating: Downgraded to Aa1, previously on 9/16/2008 published Aaa

Cl. I-A-6, Downgraded to Aa1, previously on 1/16/2008 confirmed at Aaa

Financial Guarantor: Ambac Assurance Corporation (Baa1)

Underlying Rating: Downgraded to Aa1, previously on 9/16/2008 published Aaa

Cl. I-M-1, Downgraded to A2, previously on 7/5/2004 Assigned Aa2

Cl. I-M-2, Downgraded to Baa3, previously on 7/5/2004 Assigned A2

Cl. I-M-3, Downgraded to Ba3, previously on 7/5/2004 Assigned Baa1

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Trust, Series 2004-4

Cl. I-A-4, Downgraded to Aa1, previously on 7/1/2005 Assigned Aaa

Cl. I-A-5, Downgraded to Aa2, previously on 7/1/2005 Assigned Aaa

Cl. I-A-6, Downgraded to Aa2, previously on 7/1/2005 Assigned Aaa

Cl. I-M-1, Downgraded to A3, previously on 7/1/2005 Assigned Aa2

Cl. I-M-2, Downgraded to B1, previously on 7/1/2005 Assigned A2

Cl. I-M-3, Downgraded to Ca, previously on 7/1/2005 Assigned Baa1

Cl. II-MR-3, Downgraded to Baa3, previously on 7/1/2005 Assigned Baa1

Cl. III-AR-1, Downgraded to Aa1, previously on 7/1/2005 Assigned Aaa

Cl. IV-AR-1, Downgraded to Aa2, previously on 7/1/2005 Assigned Aaa

Cl. V-AR-1, Downgraded to Aa1, previously on 7/1/2005 Assigned Aaa

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Trust, Series 2004-5

Cl. A-3, Downgraded to Aa1, previously on 10/26/2004 Assigned Aaa

Cl. A-4A, Downgraded to Aa2, previously on 2/14/2008 confirmed at Aaa

Financial Guarantor: Financial Guaranty Insurance Company (Caa1)

Underlying Rating: Downgraded to Aa2, previously on 8/21/2008 published Aaa

Cl. A-4B, Downgraded to Aa2, previously on 10/26/2004 Assigned Aaa

Cl. A-5A, Downgraded to Aa1, previously on 8/21/2008 upgraded to Aaa

Financial Guarantor: Financial Guaranty Insurance Company (Caa1)

Underlying Rating: Downgraded to Aa1, previously on 8/21/2008 published Aaa

Cl. A-5B, Downgraded to Aa1, previously on 8/21/2008 upgraded to Aaa

Financial Guarantor: Financial Guaranty Insurance Company (Caa1)

Underlying Rating: Downgraded to Aa1, previously on 8/21/2008 published Aaa

Cl. A-IO, Withdrawn, previously on 10/26/2004 Assigned Aaa

Cl. M-1, Downgraded to Baa1, previously on 10/26/2004 Assigned Aa3

Cl. M-2, Downgraded to B1, previously on 10/26/2004 Assigned A3

Cl. M-3, Downgraded to Ca, previously on 10/26/2004 Assigned Baa3

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

Excel: http://www.moodys.com/cust/getdocumentByNotesDocId.asp?criteria=PBS_SF152120

For more information please see www.moodys.com.

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

New York
Aashish Marfatia
Associate Analyst
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

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.

MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR  PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY'S PRIOR WRITTEN CONSENT.

MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.

All information contained herein is obtained by MOODY'S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided "AS IS" without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY'S is not an auditor and cannot in every instance independently verify or validate information received in the rating process or in preparing its Publications.

To the extent permitted by law, MOODY'S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY'S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY'S.

To the extent permitted by law, MOODY'S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY'S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.

NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING, ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY'S IN ANY FORM OR MANNER WHATSOEVER.

Moody's Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody's Corporation ("MCO"), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody's Investors Service, Inc. have, prior to assignment of any 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."

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 JPY250,000,000.

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

​​​​​​​​
Moodys.com