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Rating Action:

Moody's takes rating actions on 89 tranches in 15 National Collegiate student loan deals

16 Jun 2011

Approximately $9.1 billion of asset-backed securities affected.

New York, June 16, 2011 -- Moody's Investors Service downgraded 12 classes of notes and confirmed 77 classes of notes in 15 National Collegiate student loan securitizations backed by private (i.e. not government guaranteed) student loans. First Marblehead Data Services, Inc. (FMDS) and First Marblehead Education Resources, Inc., (FMER) subsidiaries of First Marblehead Corporation (FMC), are the administrator and the special servicer of the transactions, respectively.

RATINGS RATIONALE

The downgrades were prompted by elevated defaults and the consequent erosion of parity levels (i.e. the ratio of total assets to total liabilities) for the subordinate notes. For more seasoned transactions (i.e., those closed in 2004 or earlier) which should have experienced a slowdown in defaults, and therefore an increase in total parity, the parity continued to decline from a range of 86.8-94.4% in August 2010 to 85.2-92.2% in April 2011. Among the more recent transactions (i.e., those closed in 2005 or later), the total parity declined from 87.7-92.7% to 87.6-90.8% during the same period. We expect additional defaults and further declines in parity as more borrowers enter repayment.

FMC provides to Moody's supplemental static pool cumulative default information by repayment year and loan type on a quarterly basis. In March 2011, Moody's received a third-party audit of this supplemental performance information, which contained no significant exceptions.

Available credit enhancement to the transactions includes overcollateralization, reserve funds, subordination, and excess spread. Significant structural features include subordinate note interest triggers, reserve fund floors, and the change in the cash flow allocations among the senior classes upon the occurrence of certain triggers. In particular, senior notes from most trusts (other than the Master Trust, 2003-1, 2004-1, 2007-3 and 2007-4) benefit from the subordinate note interest trigger event, which redirects interest payments on the subordinate notes to principal payments on the senior notes. As of the April 2011 reporting period, the Class C interest trigger was in effect for the 2005-1, 2005-2, 2006-1, and 2006-2 transactions. In addition, the Class D interest trigger was in effect for the 2007-2 transaction.

The principal methodology used in National Collegiate Student Loan Trust rating actions was "Moody's Approach to Rating U.S. Private Student Loan-Backed Securities", published on January 6th, 2010 and is available at www.moodys.com in the Rating Methodologies sub-directory under the Research & Ratings tab. Other methodologies and factors that may have been considered in the process of rating this issue can also be found in the Rating Methodologies sub-directory on Moody's website.

Our expected lifetime net losses as a percentage of the original pool balance plus any loans added subsequently are approximately 23.9%, 28.6%, 26.3%, 31.2%, 25.8%, 31.2%, 28.6%, 29.2%, 35.9%, 30.7%, 36.2%, 33.4%, 34.4%, 33.9% and 33.8% respectively for the Master Trust, 2003-1, 2004-1, 2004-2, 2005-1, 2005-2, 2005-3, 2006-1, 2006-2, 2006-3, 2006-4, 2007-1, 2007-2, 2007-3 and 2007-4 trusts. For the trusts excluding the Master Trust and 2007-3 and 2007-4, the ratings of the most junior Class A tranches could be upgraded in the future if the lifetime expected net losses are 10% lower, or downgraded if the lifetime expected net losses are 10% higher than the levels indicated above. The ratings of Class 2005AR-16 of the Master Trust and Class A-3-AR-7 of 2007-3 and 2007-4 will not be affected in the future if the lifetime expected net losses are 10% lower or 10% higher than the levels indicated above.

The performance expectations for a given variable indicate Moody's forward-looking view of the likely range of performance over the medium term. From time to time, Moody's may, if warranted, change these expectations. Performance that falls outside the given range may indicate that the collateral's credit quality is stronger or weaker than Moody's had anticipated when the related securities ratings were issued. Even so, a deviation from the expected range will not necessarily result in a rating action nor does performance within expectations preclude such actions. The decision to take (or not take) a rating action is dependent on an assessment of a range of factors including, but not exclusively, the performance metrics. Primary sources of uncertainty with regard to expected losses are the weak economic environment and the high unemployment rate, which adversely impacts the income-generating ability of the borrowers. Overall, we expect overall a sluggish recovery in most of the world largest economies, returning to trend growth rate with elevated fiscal deficits and persistent unemployment levels. The performance of DTC loans in particular is highly sensitive to these factors. In addition, the historical loss performance data available for these pools is relatively limited particularly for the most recent securitizations, as over 90% of the borrowers in the pools were still in school when the notes were issued.

Moody's Investors Service has received and taken into account a third party due diligence report on the underlying assets or financial instruments related to the monitoring of this transaction in the past 6 months.

RATINGS

Complete rating actions are as follows:

Issuer: National Collegiate Student Loan Trust 2003-1 (The)

Cl. A-7, Confirmed at Caa1 (sf); previously on Sep 30, 2010 Downgraded to Caa1 (sf) and Remained On Review for Possible Downgrade

Cl. IO, Confirmed at Caa1 (sf); previously on Sep 30, 2010 Downgraded to Caa1 (sf) and Remained On Review for Possible Downgrade

Cl. B-1, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Cl. B-2, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2004-1

Cl. A-2, Confirmed at A3 (sf); previously on Sep 30, 2010 Downgraded to A3 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. A-4, Confirmed at Caa3 (sf); previously on Sep 30, 2010 Downgraded to Caa3 (sf) and Remained On Review for Possible Downgrade

Cl. B-1, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Cl. B-2, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2004-2

Cl. A-4, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-5-1, Confirmed at Baa2 (sf); previously on Sep 30, 2010 Downgraded to Baa2 (sf) and Remained On Review for Possible Downgrade

Cl. A-IO, Confirmed at Baa2 (sf); previously on Sep 30, 2010 Downgraded to Baa2 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa1 (sf); previously on Sep 30, 2010 Downgraded to B3 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2005-1

Cl. A-4, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5-1, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5-2, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa2 (sf); previously on Sep 30, 2010 Downgraded to B3 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2005-2

Cl. A-3, Confirmed at Aa1 (sf); previously on Apr 7, 2010 Aa1 (sf) Placed Under Review for Possible Downgrade

Cl. A-4, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5-2, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa3 (sf); previously on Sep 30, 2010 Downgraded to B3 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2005-3

Cl. A-4, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5-1, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5-2, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa1 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2006-1

Cl. A-4, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa2 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2006-2

Cl. A-2, Confirmed at Aa3 (sf); previously on Sep 30, 2010 Downgraded to Aa3 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-4, Confirmed at B1 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Remained On Review for Possible Downgrade

Cl. A-IO, Confirmed at B1 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Downgraded to Caa2 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2006-3

Cl. A-4, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-5, Confirmed at Baa2 (sf); previously on Sep 30, 2010 Downgraded to Baa2 (sf) and Remained On Review for Possible Downgrade

Cl. IO, Confirmed at Baa2 (sf); previously on Sep 30, 2010 Downgraded to Baa2 (sf) and Remained On Review for Possible Downgrade

Cl. B, Confirmed at Ba2 (sf); previously on Sep 30, 2010 Downgraded to Ba2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Downgraded to Caa2 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. D, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2006-4

Cl. A-2, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-4, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl.A-IO, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Confirmed at B2 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Downgraded to Ca (sf); previously on Sep 30, 2010 Downgraded to Caa3 (sf) and Remained On Review for Possible Downgrade

Cl. D, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2007-1

Cl. A-2, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at Baa3 (sf); previously on Sep 30, 2010 Downgraded to Baa3 (sf) and Remained On Review for Possible Downgrade

Cl. A-4, Confirmed at B1 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Remained On Review for Possible Downgrade

Cl.A-IO, Confirmed at B1 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Confirmed at B2 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. C, Downgraded to Ca (sf); previously on Sep 30, 2010 Downgraded to Caa3 (sf) and Remained On Review for Possible Downgrade

Cl. D, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2007-2

Cl. A-2, Confirmed at A1 (sf); previously on Sep 30, 2010 Downgraded to A1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at Baa1 (sf); previously on Sep 30, 2010 Downgraded to Baa1 (sf) and Remained On Review for Possible Downgrade

Cl. A-4, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl.A-IO, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Remained On Review for Possible Downgrade

Cl. B, Confirmed at B1 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Remained On Review for Possible Downgrade

Cl. C, Downgraded to Caa3 (sf); previously on Sep 30, 2010 Downgraded to B2 (sf) and Remained On Review for Possible Downgrade

Cl. D, Confirmed at Ca (sf); previously on Sep 30, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2007-3

Cl. A-2-AR-4, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-1, Confirmed at Ba2 (sf); previously on Sep 30, 2010 Downgraded to Ba2 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-2, Downgraded to Caa2 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-3, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-4, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-5, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-6, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-7, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-L, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl-A-IO, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Issuer: National Collegiate Student Loan Trust 2007-4

Cl. A-2-AR-4, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-1, Confirmed at Ba2 (sf); previously on Sep 30, 2010 Downgraded to Ba2 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-2, Downgraded to Caa3 (sf); previously on Sep 30, 2010 Downgraded to B1 (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-3, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-4, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Remained On Review for Possible Downgrade

Cl. A-3-AR-5, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-6, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-AR-7, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-IO, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Cl. A-3-L, Confirmed at Ca (sf); previously on Nov 23, 2010 Downgraded to Ca (sf) and Placed Under Review for Possible Downgrade

Issuer: The National Collegiate Master Student Loan Trust I (2001 Indenture)

Ser. NCT-2002-AR9, Confirmed at Ba1 (sf); previously on Sep 30, 2010 Downgraded to Ba1 (sf) and Placed Under Review for Possible Downgrade

Ser. NCT-2002-AR10, Confirmed at Ba2 (sf); previously on Sep 30, 2010 Downgraded to Ba2 (sf) and Placed Under Review for Possible Downgrade

REGULATORY DISCLOSURES

Information sources used to prepare the credit rating are the following: parties involved in the ratings, confidential and proprietary Moody's Investors Service information and confidential and proprietary Moody's Analytics' information.

Moody's Investors Service considers the quality of information available on the issuer or obligation satisfactory for the purposes of maintaining a credit rating.

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.

Please see ratings tab on the issuer/entity page on Moodys.com for the last rating action and the rating history.

The date on which some Credit Ratings were first released goes back to a time before Moody's Investors Service's Credit Ratings were fully digitized and accurate data may not be available. Consequently, Moody's Investors Service provides a date that it believes is the most reliable and accurate based on the information that is available to it. Please see the ratings disclosure page on our website www.moodys.com for further information.

Please see the Credit Policy page on Moodys.com for the methodologies used in determining ratings, further information on the meaning of each rating category and the definition of default and recovery.

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

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

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Moody's takes rating actions on 89 tranches in 15 National Collegiate student loan deals
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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