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Rating Action:

Moody's takes rating actions on specific issuers of the Brazilian infrastructure sector

 The document has been translated in other languages

10 Dec 2015

Action follows the placement of Brazil's Baa3 issuer and bond ratings under review for downgrade

Sao Paulo, December 10, 2015 -- Moody´s America Latina Ltda. ("Moody's") took the following rating actions on its portfolio of privately-managed toll roads as well as water, gas and electric utilities and infrastructure companies as a result of the placement of Brazil's Baa3 issuer and bond ratings, as well as the ratings on the States of Sao Paulo, Minas Gerais and Parana under review for downgrade. For more information, please see [https://www.moodys.com/research/Moodys-places-Brazils-Baa3-issuer-and-bond-ratings-on-review--PR_340103].

RATINGS RATIONALE

These actions reflect Moody's view that the recent sovereign and sub-sovereign rating actions, as a result of deteriorating economic and fiscal perspectives together with worsening governability and policy paralysis, will negatively affect the credit quality of the following companies:

Concessionária do Sistema Anhanguera-Bandeirantes S.A. (AutoBAn)

Baa2/Aaa.br issuer ratings placed under review for downgrade.

At the same time, the Baa2/Aaa.br senior unsecured ratings of the following issuances were placed under review for downgrade:

BRL500 million Brazilian debentures

BRL450 million Brazilian debentures

BRL930 million Brazilian debentures

Concessionária de Rodovias do Oeste de São Paulo -- VIAOESTE S.A.

Baa3/Aaa.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aaa.br senior unsecured ratings of the following issuances were placed under review for downgrade:

BRL440 million Brazilian debentures

BRL750 million Brazilian debentures

Concessionaria Rodovia Presidente Dutra S.A.

Baa3/Aa1.br issuer ratings placed under review for downgrade.

Concessionária de Rodovias do Interior do Oeste S.A. (SPVias)

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aa1.br senior unsecured ratings of the BRL190 million Brazilian debentures were placed under review for downgrade.

Autovias S.A.

Baa3/Aa1.br issuer rating placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL120 million senior debentures due in 2017 were placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL300 million senior debentures due in 2017 were placed under review for downgrade.

Concessionária de Rodovias do Interior Paulista S.A.

Baa3/Aa1.br issuer rating placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL600 million senior debentures due in 2018 were placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL375 million senior debentures were placed under review for downgrade.

EATE -- Empresa Amazonense Transmissão Energia SA

Baa3/Aaa.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aaa.br ratings on the following debenture issuances were place under review for downgrade:

BRL 295 million due 2016

BRL159 million due 2020

BRL 150 million due 10/19/2017

ETEP - Empresa Paraense Transmissão de Energia

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL 69 million debentures due 2020 were placed under review for downgrade.

ENTE - Empresa Norte de Transmissão de Energia SA

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the following debenture issuances were placed under review for downgrade:

BRL 248 million due 2020

BRL 145 million due 2015

Transmissora Aliança de Energia Elétrica S.A. -- TAESA

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on BRL 425 million and BRL 245 million senior unsecured debentures were placed under review for downgrade.

Ratings Ba1/Aa2.br on BRL 145 million subordinated debentures were also placed under review for downgrade.

Companhia Energética de Minas Gerais -- CEMIG

Ba1/Aa2.br issuer ratings placed under review for downgrade.

CEMIG Distribuição S.A.

Ba1/Aa2.br issuer ratings placed under review for downgrade.

At the same time, the Ba1 on the global scale and Aa2.br on the national scales of the following issuances were placed under review for downgrade:

Backed senior unsecured BRL653.67 million Brazilian debentures

Backed senior unsecured BRL1,095.51 million Brazilian debentures

Backed senior unsecured BRL410.82 million Brazilian debentures

CEMIG Geração e Transmissão S.A.

Ba1/Aa2.br Corporate Family Ratings (CFR) placed under review for downgrade.

At the same time, the Ba1 on the global scale and Aa2.br on the national scales of the following issuances were placed under review for downgrade:

Backed senior unsecured BRL670 million Brazilian debentures

Backed senior unsecured BRL972.75 million Brazilian debentures

Backed senior unsecured BRL480 million Brazilian debentures

Backed senior unsecured BRL27.25 million Brazilian debentures

Backed senior unsecured BRL1,400 million in Brazilian debentures

Backed senior unsecured BRL200 million in Brazilian debentures

Backed senior unsecured BRL349.60 million in Brazilian debentures

Bandeirante Energia SA

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Ba1/Aa2.br ratings on the BRL 390 million subordinated debentures due 07/01/2016 were placed under review for downgrade.

Espirito Santo Centrais Eletricas -- Escelsa

Baa3/Aa1.br issuer ratings placed under review for downgrade..

Companhia de Gás de São Paulo -- COMGÁS

Baa3/Aa1.br issuer rating placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL500 million senior debentures due in 2025 were placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL540 million senior debentures due in 2020 were placed under review for downgrade.

Energest SA

Baa3/Aa1.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL 120 million senior debentures due 04/24/2017 were placed under review for downgrade.

Duke Energy International Geração Paranapanema SA

Baa3/Aaa.br issuer ratings placed under review for downgrade.

At the same time, the Baa3/Aaa.br ratings on the following debenture issuances were place under review for downgrade:

BRL 239 million due 2019

BRL 240 million due 2021

BRL 250 million due 07/16/2018

BRL 250 million due 07/16/2023

BRL 150 million due 2017

AES Tiete S.A.

Baa3/Aa1.br issuer rating placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL498 million senior debentures due in 2019 were placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL440 million senior debentures due in 2022 were placed under review for downgrade.

At the same time, the Baa3/Aa1.br ratings on the BRL300 million senior debentures due in 2020 were placed under review for downgrade.

Companhia de Saneamento do Paraná - Sanepar

Ba1/Aa2.br issuer rating placed under review for downgrade.

At the same time, the Ba1/Aa2.br ratings on the BRL300 million senior debentures due in 2020 were placed under review for downgrade.

Companhia de Saneamento de Minas Gerais S.A. -- COPASA

Corporate Family Rating (CFR) of Ba1/Aa2.br, placed under review for downgrade.

Ratings on BRL200million in Brazilian debentures due in 2017, BRL200million in Brazilian debentures due in 2019, BRL350million in Brazilian debentures issued in August 2015, and BRL250million in Brazilian debentures issued in February 2015 of Ba1/Aa2.br placed under review for downgrade

WHAT COULD CHANGE THE RATING UP/DOWN

Since these ratings are currently under review for downgrade an upgrade of the ratings is unlikely in the near term.

Further deterioration in the respective sovereign or sub-sovereign's credit quality could exert downward pressure on these infrastructure issuers. A downgrade would be triggered if Moody's perceives a further deterioration in the level of governmental support as well as the consistency and predictability of the relevant regulatory frameworks of the country and/or states under which these companies operate. Political interference in the normal course of business of these issuers could also be considered a trigger for a downgrade.

The principal methodology used in rating CEMIG Distribuição S.A., CEMIG Geração e Transmissão S.A., Bandeirante Energia SA, Espirito Santo Centrais Eletricas -- Escelsa, Cia de Gas de Sao Paulo - COMGAS was Regulated Electric and Gas Utilities published in December 2013.

The principal methodology used in rating Conc Sist Anhang-Bandeirant S.A. Autoban, Concessionaria Rod.Oeste SP Viaoeste S.A., Concessionaria Rodovia Pres. Dutra S.A., Concessionaria de Rod Int do Oest SA (SPVias), Autovias S.A. and Concessionaria de Rodovias Interior Paulista was Privately Managed Toll Roads published in May 2014.

The principal methodology used in rating EATE - Emp. Amazonense Trans. Energ. S.A., ETEP - Empresa Paraense Transmissão de Energia S.A., ENTE - Empresa Norte de Transmissão de Energia S.A. and Transmissora Aliança de Energia Elétrica S.A. -- TAESA was Regulated Electric & Gas Networks published in November 2014.

The methodologies used in rating Companhia Energética de Minas Gerais -- CEMIG were Regulated Electric and Gas Utilities published in December 2013, and Government-Related Issuers methodology published in October 2014.

The methodologies used in rating Companhia de Saneamento do Parana -- SANEPAR and Companhia de Saneamento de Minas Gerais S.A. -- COPASA were Global Regulated Water Utilities published in December 2009, and Government-Related Issuers methodology published in October 2014.

The principal methodology used in rating Energest SA, Duke Energy International Geração Paranapanema AS and AES Tiete S.A. was Unregulated Utilities and Unregulated Power Companies published in October 2014. Please see the Credit Policy page on www.moodys.com.br for a copy of these methodologies.

Moody's National Scale Credit Ratings (NSRs) are intended as relative measures of creditworthiness among debt issues and issuers within a country, enabling market participants to better differentiate relative risks. NSRs differ from Moody's global scale credit ratings in that they are not globally comparable with the full universe of Moody's rated entities, but only with NSRs for other rated debt issues and issuers within the same country. NSRs are designated by a ".nn" country modifier signifying the relevant country, as in ".za" for South Africa. For further information on Moody's approach to national scale credit ratings, please refer to Moody's Credit rating Methodology published in June 2014 entitled "Mapping Moody's National Scale Ratings to Global Scale Ratings".

REGULATORY DISCLOSURES

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

Moody's considers the quality of information available on the rated entity, obligation or credit satisfactory for the purposes of issuing a rating.

Moody's adopts all necessary measures so that the information it uses in assigning a 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.

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

Please see the ratings disclosure page on www.moodys.com.br for general disclosure on potential conflicts of interests.

Moody's America Latina Ltda. may have provided Other Permissible Service(s) to the rated entity or its related third parties within the 12 months preceding the credit rating action. Please see the special report "Services provided to entities rated by Moody's America Latina Ltda." on our website www.moodys.com.br for further information.

Entities rated by Moody's America Latina Ltda. (and the rated entities' related parties) may also receive products/services provided by parties related to Moody's America Latina Ltda. engaging in credit ratings activities. Please go to www.moodys.com.br for a list of entities receiving products/services from these related entities and the products/services received. This list is updated on a quarterly basis.

CCR Group, which comprises Conc Sist Anhang-Bandeirant S.A. Autoban, Concessionaria de Concessionaria Rod.Oeste SP Viaoeste S.A., Concessionaria Rodovia Pres. Dutra S.A. and Concessionaria de Rod Int do Oest SA (SPVias) rated in this Press Release, accounted for 5% or more of the annual revenue of Moody's America Latina, Ltda. during the preceding calendar year.

Arteris Group, which comprises Autovias S.A. and Concessionaria de Rodovias Interior Paulista rated in this Press Release, accounted for 5% or more of the annual revenue of Moody's America Latina, Ltda. during the preceding calendar year.

Alupar Group, which comprises EATE - Emp. Amazonense Trans. Energ. S.A., ETEP – Emp Paranaense Transmissão de Energia and ENTE – Empresa Norte de Transmissão de Energia rated in this Press Release, accounted for 5% or more of the annual revenue of Moody's America Latina, Ltda. during the preceding calendar year.

The date of the last Credit Rating Action for Conc Sist Anhang-Bandeirant S.A. Autoban was 27/08/2015.

The date of the last Credit Rating Action for Concessionaria Rod.Oeste SP Viaoeste S.A. was 12/08/2015.

The date of the last Credit Rating Action for Concessionaria Rodovia Pres. Dutra S.A. was 12/08/2015.

The date of the last Credit Rating Action for Concessionaria de Rod Int do Oest SA (SPVias) was 12/08/2015.

The date of the last Credit Rating Action for Autovias S.A. was 12/08/2015.

The date of the last Credit Rating Action for Concessionaria de Rodovias Interior Paulista was 12/08/2015.

The date of the last Credit Rating Action for EATE - Emp. Amazonense Trans. Energ. S.A. was 12/08/2015.

The date of the last Credit Rating Action for ETEP - Empresa Paraense Transmissão de Energia was 18/07/2014.

The date of the last Credit Rating Action for ENTE - Empresa Norte de Transmissão de Energia SA was 18/07/2014.

The date of the last Credit Rating Action for Transmissora Aliança de Energia Elétrica S.A. -- TAESA was 28/07/2015.

The date of the last Credit Rating Action for Companhia Energética de Minas Gerais -- CEMIG was 18/11/2014.

The date of the last Credit Rating Action for CEMIG Distribuição S.A. was 15/10/2014.

The date of the last Credit Rating Action for CEMIG Geração e Transmissão S.A. was 17/06/2015.

The date of the last Credit Rating Action for Bandeirante Energia SA was 06/03/2015.

The date of the last Credit Rating Action for Espirito Santo Centrais Eletricas -- Escelsa was 02/06/2015.

The date of the last Credit Rating Action for Cia de Gas de Sao Paulo - COMGAS was 10/11/2015.

The date of the last Credit Rating Action for Energest SA was 06/03/2015.

The date of the last Credit Rating Action for Duke Energy International Geração Paranapanema SA was 11/04/2014.

The date of the last Credit Rating Action for AES Tiete S.A. was 30/10/2015.

The date of the last Credit Rating Action for Companhia de Saneamento do Parana - SANEPAR was 12/08/2015.

The date of the last Credit Rating Action for Companhia de Saneamento de Minas Gerais S.A. -- COPASA was 10/08/2015.

Moody's ratings are constantly monitored, unless designated as point-in-time ratings in the initial press release. All Moody's ratings are reviewed at least once during every 12-month period.

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.br.

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 ratings tab on the issuer/entity page on www.moodys.com.br for the last rating action and the rating history. The date on which some ratings were first released goes back to a time before Moody's ratings were fully digitized and accurate data may not be available. Consequently, Moody's 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.br for further information.

Please see Moody's Rating Symbols and Definitions on the Rating Process page on www.moodys.com.br for further information on the meaning of each rating category and the definition of default and recovery.

The below contact information is provided for information purposes only. Please see the ratings tab of the issuer page at www.moodys.com.br, for each of the ratings covered, Moody's disclosures on the lead analyst and the Moody's legal entity that has issued the ratings.

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

Please see www.moodys.com.br 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 .br for additional regulatory disclosures for each credit rating.

Alexandre De Almeida Leite
VP - Senior Credit Officer
Infrastructure Finance Group
Moody's America Latina Ltda.
Avenida Nacoes Unidas, 12.551
16th Floor, Room 1601
Sao Paulo, SP 04578-903
Brazil
JOURNALISTS: 800-891-2518
SUBSCRIBERS: 55-11-3043-7300

William L. Hess
MD - Utilities
Infrastructure Finance Group
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Releasing Office:
Moody's America Latina Ltda.
Avenida Nacoes Unidas, 12.551
16th Floor, Room 1601
Sao Paulo, SP 04578-903
Brazil
JOURNALISTS: 800-891-2518
SUBSCRIBERS: 55-11-3043-7300

Moody's takes rating actions on specific issuers of the Brazilian infrastructure sector
No Related Data.
© 2019 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 ITS RATINGS AFFILIATES (“MIS”) ARE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MOODY’S PUBLICATIONS MAY INCLUDE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY’S 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 RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY’S 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. CREDIT RATINGS AND MOODY’S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY’S PUBLICATIONS COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS AND PUBLISHES MOODY’S 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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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.

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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 rating, agreed to pay to Moody’s Investors Service, Inc. for ratings opinions and services rendered by it fees ranging from $1,000 to approximately $2,700,000. MCO and MIS also maintain policies and procedures to address the independence of MIS’s ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold ratings from MIS 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 rating, agreed to pay to MJKK or MSFJ (as applicable) for 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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