Credit Policy. Default & Loss Rates of Structured Finance Securities: Special Comment. Moody s Global. Summary Opinion.

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1 Special Comment Moody s Global Credit Policy July 2008 Table of Contents: Summary Opinion 1 Issuance and Distribution of Global Structured Finance Ratings Material Impairments 3 Sector Specific Analysis of Impairments 9 Loss-Given-Default on Principal-Impaired Tranches and Historical Average Loss Rates 19 Appendix I: Description of Data Sample and Glossary 24 Appendix II: How to Calculate Multi-Year Material Impairment Rate and LGD Rate 28 Appendix III: Material Impairment Rates 32 Appendix IV: Principal Impairment Rates 36 Appendix V: Estimated Historical Average Loss Rates 40 Appendix VI: One-Year Rating Transition Matrix with a Principal Impairment Column 44 Moody s Related Research 46 Analyst Contacts: New York Kumar Kanthan Senior Vice President 0 Julia Tung Vice President/Senior Credit Officer 0 Matthew Woolley Assistant Vice President/Analyst 0 Richard Cantor Group Managing Director 0 Nicolas Weill Structured Finance Chief Credit Officer London David Rosa Vice President/Senior Credit Officer Default & Loss Rates of Structured Finance Securities: Summary Opinion This Special Comment presents Moody's sixth annual report of the material impairment and loss rates of global structured finance securities, covering the credit performance through year-end 2007 of all structured finance securities issued since The following are the highlights of this report: The number of newly impaired tranches rose sharply to 2,090 in 2007 from in Of these, 1,780 suffered principal losses or were downgraded to Ca or C ("principal impairments"), while 310 experienced only interest shortfalls ("interest impairments"), compared to 99 principal impairments and 9 interest impairments in the prior year. The sharp rise in impairments saw more impairments, both interest-only and principal, than the previous 14 years combined can be attributed to the US housing crisis, spawned by nationwide US home price declines combined with a sudden tightening of credit standards and rising interest rates. The length and depth of the current prolonged US housing crisis means that impairments rates in 2008 should be expected to be at similarly elevated levels. Not surprisingly, the 2007 impairments were concentrated in securities associated with the US residential mortgage sector, with US HEL and Global SF CDOs accounting for 66% and 25% of impairments for the year respectively. Final loss severity rates (LGDs) on impaired securities have averaged 66% as a share of original balances for the 789 principal-impaired securities since 1993 that have reached a resolution (i.e., with no remaining principal balance) as of year-end Within that universe, tranches backed by Subprime Seconds and HELOCs have fared particularly poorly with average LGDs of around 90%. 1 The number of impaired securities in 2006 has been revised down due to cures.

2 Issuance and Distribution of Global Structured Finance Ratings A total of 22,465 new structured finance ratings were issued in The number declined for the first time since 1998 and was down 20% from the peak issuance observed in As shown in Exhibit 1, the decline was largely driven by lower issuance in the mortgage-backed sectors with US HEL, US RMBS, and US CMBS new issuance down almost 44%, 19%, and 13%, respectively, compared to 2006 levels. In contrast, US ABS excluding HEL, Global CDOs, and the Intl SF sectors saw mild increases in rated issuance with gains limited to 3.5% or less. 2 Exhibit 1: Number of New Ratings by Issuance Year 30,000 25,000 20,000 15,000 10,000 5, US ABS ex HEL US HEL US RMBS US CMBS Global CDOs Intl SF ex CDOs & Other SF Other SF Although the growth of new issuance was down in 2007 from 2006 levels, the number of newly rated structured instruments was still relatively high and contributed to the overall increase in the number of outstanding ratings at the beginning of 2008 (104,235). Exhibit 2 shows the number of outstanding ratings at the beginning of each year from 1994 to As seen in the chart, the number of outstanding ratings has grown rapidly over the years and totaled 86,671 at the beginning of US RMBS has had the largest proportion of outstanding ratings of all sectors in all years. Exhibit 2: Number of Ratings Outstanding at the Beginning of Each Year 90,000 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10, US ABS ex HEL US HEL US RMBS US CMBS Global CDOs Intl SF ex CDOs & Other SF Other SF 2 Note that the criteria used to create the data set for this report has changed from prior years. The most notable changes are that pari passu tranches are no longer collapsed and wrapped tranches are included. For a more detailed description of the data sample and calculation methods, please see the Appendix. 2 July 2008 Special Comment -

3 The distribution of ratings among the various asset classes remained quite stable from 2006 to 2007; US ABS, excluding HEL, saw its share fall by 2.7 percentage points, while US RMBS increased its share by the same amount (see Exhibit 3A). Slightly more than 60% of all outstanding ratings at the beginning of 2007 were in the US RMBS and HEL sectors, underscoring the concentrated exposure of global structured finance to the US housing market. The distribution of ratings outstanding remained heavily skewed towards the Investment Grade (IG) end of the spectrum, with slightly over 50% of all outstanding ratings as of 1/1/2007 in the Aaa category. Indeed, IG ratings made up 91.8% of all structured ratings at the start of Exhibit 3: Distribution of Outstanding Ratings on 1/1/2007 Exhibit 3B: By Rating EM EA SF ex. CDO & Other SF 5.6% Other SF 0.5% Global CDOs 13.4% Exhibit 3A: By Sector Other Intl SF ex CDO & Other SF 2.5% US A B S ex HEL 8.6% US HEL 25.5% Ba 5.2% Baa 14.0% A 13.4% B 1.7% Caa-C 1.3% Aaa 50.5% US CM B S 9.3% Total: 86,671 US RM B S 34.6% Aa 13.9% Total: 86, Material Impairments Structured Finance Material Impairments Moody s first introduced the concept of material impairment in 2003 in order to differentiate the definition of default between corporate and structured finance sectors. 3 Material impairments fall into one of two categories, principal impairments and interest impairments. Principal impairments include securities that have suffered principal write-downs or principal losses at maturity and securities that have been downgraded to Ca/C, even if they have not yet experienced an interest shortfall or principal write-down. 4 Interest impairments, or interest-impaired securities, include securities that are not principal impaired and have experienced only interest shortfalls. The actual impairment classification is based on a security s status at the end of the study period. For example, a security that initially experienced an interest shortfall before suffering a principal write-down several months later would be classified as a principal impairment with impairment date equal to when the interest shortfall occurred. If, however, the interest shortfall is cured before the principal write-down occurs, then the impairment date coincides with the date of the principal write-down. Moody s does not treat tranches that are under-collateralized or implicitly construed to be written down as material impairments, but tranches that are not paying current interest, but rather paying in kind (PIKing) are considered to be materially impaired. 3 4 See Moody's Special Comment, "Payment Defaults and Material Impairments of U.S. Structured Finance Securities: ," December Securities that have been downgraded to Ca/C are virtually certain to sustain losses ultimately. 3 July 2008 Special Comment -

4 2007 Material Impairment Summary 2007 saw more impairments, both interest-only and principal, than the previous 14 years combined (see Exhibit 4). US home price declines, combined with tightening credit standards and rising interest rates, contributed to a large number of impairments of securities associated with the US residential mortgage sector. Credit markets seized, leading to extensions of extendible ABCP programs and the outright failure of the SIV market as sponsors were unable to issue new liabilities. Exhibit 4 presents the total number of material impairments by year of impairment. A total of 2,090 securities were newly impaired in 2007, of which 1,780 were principal impairments and 310 were interest impairments. Note that interest impairments are relatively infrequent in prior years. We designate bonds that have experienced interest impairments as either cured (with no impairment) if interest shortfalls are cured or principal impaired once they become principal impaired. As can be seen from the chart, there are very few interest impairments that did not either eventually become principal impairments or become cured. Exhibit 4: Structured Finance Material Impairments by Impairment Year 1,800 1,600 1,400 1,200 1, Principal Impairment Interest Impairment At 37.2%, US HEL suffered by far the highest trailing 12-month speculative grade (SG) impairment rate (see Exhibit 5), and as US HEL represents roughly one quarter of the total global structured universe, the overall trailing 12-month SG impairment rate was 11.3%. Exhibit 5: 2007 Material Impairments 5 Count of Impairments in month Impairment Rate for 2007 Principal Impairments Interest Impairments Total Investment Grade Speculative Grade US ABS ex HEL % 4.6% 0.3% US HEL (includes subprime) 1, , % 37.2% 5.1% US RMBS (includes Alt-A) % 5.1% 0.4% US CMBS % 0.7% 0.2% Global CDOs % 6.4% 2.9% Other Structured Finance % 0.0% 3.7% EMEA ex CDO and Other SF % 1.1% 0.1% Other Intl ex CDO and Other SF % 0.0% 0.0% Global Structured Finance 1, , % 11.3% 1.9% All 5 Note that the 12-month impairment rates provided in this table and throughout the report do not take into account those newly impaired securities that were issued in 2007 as the last cohort was formed at the beginning of Please refer to Exhibit 6B for more information about the distribution of new impairments by vintage. 4 July 2008 Special Comment -

5 The distribution of 2007 material impairments in three different dimensions is summarized below in Exhibit 6. Exhibit 6A shows the distribution of impairments by sector and is a graphical version of the Total column in Exhibit 5. Again, US HEL comprises the majority of impairments at 66.2% of total impairments, while Global CDOs are second with 25.7% of 2007 impairments. Within the Global CDO sector, over 96% of 2007 impairments were from the structured finance CDO subsector and around 2% were from the market value CDO subsector, with only 1% related to corporate CLOs and CBOs. Slicing the 2007 impairment sample by vintage (Exhibit 6B) shows the heightened risk of the 2006 and 2007 vintages. Over 60% of 2007 impairments came from the 2006 vintage, and the already poor performance of 2007 vintage issuance is demonstrated by its 21% share of 2007 material impairments. That is, of the 2,090 impaired tranches in 2007, 436 were issued in The poor performance of 2007 vintage tranches (for certain asset classes) so soon after issuance suggests dim prospects for the overall performance of 2007 vintage issuance in 2008 and beyond. Exhibit 6C indicates that roughly 2/3 of securities impaired in 2007 originally held investment grade ratings. Exhibit 6: Distribution of Material Impairments in 2007 Exhibit 6A: By Sector Exhibit 6B: By Vintage Exhibit 6C: By Original Rating Global CDOs 25.7% Intl SF ex CDO & Other SF 0.1% Other SF 1.0% US A B S ex HEL 1.0% % pre % % % % B 1.2% Caa-C 0.0% Aaa 2.5% Aa 3.1% A 12.1% US CMBS 0.6% % Ba 33.6% US RMBS 5.4% US HEL 66.2% % Baa 47.4% Total Number of Impairments: 2,090 The poor performance of the US HEL sector in 2007 is put into perspective when compared to the distribution of all material impairments prior to 2007 (Exhibit 7). US HEL comprises only about 19% of the pre-2007 impairment experience, while about 40% of historical impairments have been attributed to US ABS ex. HEL, particularly the manufactured housing, franchise loan, and equipment lease subsectors (84% of all historical US ABS ex. HEL impairments). 5 July 2008 Special Comment -

6 Exhibit 7: Distribution of Material Impairments prior to 2007 Exhibit 7A: By Sector Exhibit 7B: By Vintage Exhibit 7C: By Original Rating Global CDOs 27.0% Intl SF ex CDO & Other SF 0.8% US A B S ex HEL 39.2% % % post % pre % % B 14.1% Caa 0.9% Aaa 4.0% Aa 8.9% A 11.6% US CMBS 9.4% US RMBS 4.8% US HEL 18.8% % % % Ba 20.1% Baa 40.4% Total Number of Impairments: 1,217 The distribution of impairments prior to 2007 is reasonably well-diversified among various vintages with the vintages performing better than any single-year vintage (excluding the pre-1997 experience). The high number of 2006 and 2007 vintage impairments is both a natural result of the rapid expansion of the structured finance market to date, and the poor performance of many securities from these vintages. When examined through the lens of original rating, however, the 2007 impairment experience does not look as divergent from historical trends. Indeed, a plurality of impairments were originally rated in the broad Baa category both in the 2007 and prior-to-2007 samples. The 2007 sample actually has a lower share of impairments that were rated Aaa-A, relative to the historical average, and a higher share of 2007 impairments came from the Baa and Ba categories, again relative to the historical experience. The time-series plots of trailing 12-month impairment rates shown in Exhibit 8 put into relief the recent deterioration of the performance of A- and Baa-rated tranches. Both A- and Baa-rated tranches have hit alltime high impairment rates in the most recent cohorts, and the SG impairment rate is at the previous high of 11.3% reached by the cohort ending in January The Aaa cohort has reached its previous high of 0.1% as well, and the result of such poor performance by virtually all rating classes is an all-time high trailing 12- month impairment rate for the entire rated universe. 6 July 2008 Special Comment -

7 Exhibit 8: Trailing 12-Month Impairment Rates by Cohort Rating Exhibit 8A: Trailing 12-month Impairment Rates by Rating (Aaa, Aa, A) 1.6% 1.4% 1.2% 1.0% 0.8% 0.6% 0.4% 0.2% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Dec-03 Dec-05 Dec-07 Cohort End Month Aaa Aa A Exhibit 8B: Trailing 12-month Impairment Rates by Rating (Baa, SG, All) 12% 10% 8% 6% 4% 2% 0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Dec-03 Dec-05 Dec-07 Cohort End Month Baa SG All The weak performance of the 2006 and 2007 vintages is also highlighted by Exhibit 9 which shows that, in terms of number of impairments, those vintages have already surpassed all prior vintages. In terms of cumulative impairment rates, the 2006 vintage ranks fourth-highest among all the vintages, after just two years of impairment experience. Similarly, the 2007 vintage, after just one year of impairment experience, has already surpassed the cumulative impairment rates of six prior vintages. 7 July 2008 Special Comment -

8 Exhibit 9: Structured Finance Material Impairments by Closing Year 1,400 1,200 1, % 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% % Number of Impairments Cumulative Impairment Rate Exhibit 10 provides a longer historical look at the breakdown of issuance and cumulative impairment rates among broad rating categories, and illustrates that the vast majority of issuance by volume (87%) has been originally rated Aaa. 6 Aa, A, and Baa issuance represent 5%, 4%, and 3% shares of total historical issuance, respectively, while speculative grade issuance is less than 1% of all structured issuance. Exhibit 10: Cumulative Material Impairment Rate by Original Rating and Volume 14, % 12.84% 12, % 10, % US $ billions 8,000 6,000 4, % 8.18% 3.47% 8.0% 6.0% 4.0% 2, % 1.68% 0.48% 0.10% Aaa Aa A Baa Ba B Caa All Total Issuance (as of 2007) Cumulative Impairment Rate (as of 2007) 2.0% 0.0% Cumulative impairment rates increase as rating decreases down to the Ba category, at which point cumulative impairment rates fall. This may seem counterintuitive at first, but the non-monotonicity can be explained by looking at the small amount of originally-rated Ba and Caa securities. Indeed, B- and Caa-rated issuance represents only 0.16% of the total amount, so a relatively small number of well- or poorly-performing low-rated tranches are enough to cause large swings in cumulative impairment rates for those rating categories. 6 Note: Other SF is excluded from the volume calculations in Exhibit 10 as historical issuance in this category is not as well catalogued. 8 July 2008 Special Comment -

9 Sector Specific Analysis of Impairments US ABS ex. HEL Although there were slightly more interest impairments in 2007 than 2006, there were fewer principal and overall impairments in the US ABS ex. HEL asset class (see Exhibit 11). Indeed, when the total size of the sector is taken into account, the impairment rates are at-or-near all-time lows for virtually all rating categories. Exhibit 11: US ABS ex HEL Material Impairment Trends Exhibit 11A: Number of Impairments by Impairment Year Principal Impairment 2001 Impairment Year Interest Impairment 2007 Exhibit 11B: Impairments by Closing Year % % % % % % 0 0.0% Closing Year Impairment Count Cum Impairment Rate Exhibit 11C: Trailing 12-Month Impairment Rates by Rating (Aaa, Aa, A) 7.0% 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Aaa Aa A Dec-05 Dec-07 Exhibit 11D: Trailing 12-Month Impairment Rates by Rating (Baa, SG, All) 50% 40% 30% 20% 10% 0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Baa SG All Dec-05 Dec-07 Of the twenty 2007 US ABS ex. HEL impairments, 14 were in aircraft lease deals, 3 were backed by equipment leases, and the remaining 3 were related to other asset classes. All of the 2007 impairments were associated with deals that closed in 2002 or earlier, showing that the phenomenon of weak performance of 2006 and 2007 vintages has not been evident so far in the US ABS ex. HEL sector. The distribution of historical US ABS ex. HEL impairments by asset type (see Exhibit 12), reveals that the three major asset classes student loans, autos, and credit cards have experienced few impairments while a vast majority of the impairments are accounted for by a few troubled sectors including: health care receivables, mutual fund fees, franchise loans, manufactured housing (MH), aircraft lease, and equipment lease. 9 July 2008 Special Comment -

10 Exhibit 12: Cumulative Impairment Rates for US ABS by Asset Type 80% 70% 60% 61.5% 50% 40% 33.3% 30% 20% 10% 0% 0.0% 0.3% 0.5% 0.8% 5.6% 18.3% 20.5% 22.1% Student Loan Auto Credit Card Small Bus Loan Equipment Lease Aircraft Lease MH Franchise Loan Mutual Fund Fees Health Care Rec By Count By Volume US HEL US HEL experienced both the highest share of impairments in 2007 relative to other asset classes, and the poorest performance relative to the historical record of the asset class (see Exhibit 13). The total number of new impairments in 2007 amounted to 1,384, far exceeding the sum of all the historical impairments in the sector. Of those new impairments, all of which were principal impairments, 84% were from the 2006 and 2007 vintages. Aaa-rated securities experienced no impairments during the year, but the trailing 12-month impairment rates rose sharply for both the investment-grade and speculative-grade ratings categories. A more detailed analysis of impairments in the US HEL and US RMBS sectors is found on pages Exhibit 13: US HEL Material Impairment Trends Exhibit 13A: Number of Impairments by Impairment Year Principal Impairment 2001 Impairment Year Interest Impairment 2007 Exhibit 13B: Impairments by Closing Year Impairment Count 2001 Closing Year Cum Impairment Rate 14% 12% 10% 8% 6% 4% 2% 0% 10 July 2008 Special Comment -

11 Exhibit 13C: Trailing 12-Month Impairment Rates by Rating (Aaa, Aa, A) 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Aaa Aa A Dec-05 Dec-07 Exhibit 13D: Trailing 12-Month Impairment Rates by Rating (Baa, SG, All) 60% 50% 40% 30% 20% 10% 0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Baa SG All Dec-05 Dec-07 US RMBS The total number of new impairments in the US RMBS sector in 2007 amounted to 112 (see Exhibit 14). Similar to the US HEL sector, the number of new impairments far exceeded the sum of all the historical impairments in the sector. Of those new impairments, all of which were principal impairments, 64% were from the 2006 and 2007 vintages, and an additional 21% were from the 2005 vintage. Approximately 85% of the new US RMBS impairments occurred within the Alt-A subsector, while only one of the impairments, a security issued in 2002, was backed by Jumbo/Prime collateral. Exhibit 14: US RMBS Material Impairment Trends Exhibit 14A: Number of Impairments by Impairment Year Principal Impairment 2001 Impairment Year Interest Impairment Exhibit 14B: Impairments by Closing Year Closing Year Impairment Count % 0.8% 0.7% 0.6% 0.5% 0.4% 0.3% 0.2% 0.1% 0.0% Cum Impairment Rate 11 July 2008 Special Comment -

12 Exhibit 14C: Trailing 12-Month Impairment Rates by Rating (Aaa, Aa, A) 0.6% 0.5% 0.4% 0.3% 0.2% 0.1% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Aaa Aa A Dec-05 Dec-07 Exhibit 14D: Trailing 12-Month Impairment Rates by Rating (Baa, SG, All) 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Baa SG All Dec-05 Dec-07 Of the new impairments, only one was related to a Aa-rated security and only two were related to A-rated securities, with the vast majority of impairments concentrated in securities rated Baa and lower. That breakdown can be seen in the trailing 12-month impairment rates chart which shows the sharpest rise in impairment rates for Baa securities and for the broad SG rating category. US RMBS and HEL Impairments by Loan Type and Vintage Drilling further into the 2007 US RMBS and HEL impairments (see Exhibit 15), we see that the highest number of impairments involved securities backed by subprime first liens, followed by subprime seconds, and then by Alt-A transactions. The fewer number of impairments among subprime seconds rather than subprime firsts transactions is more indicative of the relative sizes of the two sectors rather any suggestion of better performance among subprime seconds. In fact, in terms of impairments involving a payment shortfall, 439 of the 516 impaired securities backed by subprime seconds experienced a payment shortfall by the end of 2007 versus 125 of the 850 impaired securities backed by subprime firsts, an indication of the increased speed at which losses were accumulating for subprime second transactions. Exhibit 15: US RMBS/HEL Impairments in 2007 by Loan Type Alt-A Subprime Firsts Subprime Seconds Re-performing, Scratch & Dent Payment Shortfall Ca/C w ith no Payment Shortfall Other RMBS/HEL 12 July 2008 Special Comment -

13 The impairment performance of the worst performing vintages (2005 to 2007) for the worst performing sectors (subprime firsts, subprime seconds, and Alt-A) is broken out by rating category in Exhibit 16 to Exhibit 18. In terms of cumulative impairments, for subprime firsts and subprime seconds transactions, the 2005 vintage has seen the best performance, the 2006 vintage has seen the worst performance, and the 2007 vintage performance has been in between, though given its low amount of seasoning, it may ultimately perform worse than the 2006 vintage as time passes. The 2006 vintage of subprime seconds has seen 88%, 50%, and 9.8% impairment rates of Baa, A, and Aa securities respectively. The 2006 vintage of subprime firsts has performed better in relative terms with impairment rates of 18%, 0.1%, and 0.0% among Baa, A, and Aa securities respectively. In relative terms, the 2006 vintage of Alt-A deals has performed even better with only a 5% impairment rate for Baa securities and no impairments among A- and higher-rated securities. For Alt-A transactions, the 2007 vintage has been the best performing in terms of cumulative impairments, having seen no impairments to date. Exhibit 16: Impairments among Subprime First Lien Backed US HEL Subprime First 2005 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 2, % 0 348, % Aa 0 1, % 0 36, % A 0 1, % 0 19, % Baa 0 1, % 0 13, % Ba % 31 3, % B % % Total 4 5, % , % Subprime First 2006 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 2, % 0 347, % Aa 0 1, % 0 40, % A 1 1, % 13 21, % Baa 234 1, % 2,763 14, % Ba % 3,078 4, % B 0 0 NA 0 0 NA Total 537 6, % 5, , % Subprime First 2007 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 1, % 0 143, % Aa % 0 17, % A % 79 8, % Baa % 1,249 6, % Ba % 759 1, % B % % Total 183 3, % 2, , % 13 July 2008 Special Comment -

14 Exhibit 17: Impairments among Subprime Second Lien Backed US HEL Subprime Second 2005 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa % 0 14, % Aa % 0 2, % A % 0 1, % Baa % 130 1, % Ba % % B 0 0 NA 0 0 NA Total % , % Subprime Second 2006 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa % 0 23, % Aa % 309 3, % A % 805 1, % Baa % 1,281 1, % Ba % % B 0 0 NA 0 0 NA Total % 3,065 31, % Subprime Second 2007 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa % 0 9, % Aa % % A % % Baa % % Ba % % B 0 0 NA 0 0 NA Total % , % 14 July 2008 Special Comment -

15 Exhibit 18: Impairments among Alt-A Backed US HEL Alt-A 2005 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 4, % 0 363, % Aa % 0 13, % A % 0 5, % Baa % 93 3, % Ba % % B % % Total 23 7, % , % Alt-A 2006 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 4, % 0 369, % Aa 0 1, % 0 15, % A % 0 5, % Baa % 158 3, % Ba % % B % % Total 64 8, % , % Alt-A 2007 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa 0 3, % 0 216, % Aa % 0 9, % A % 0 2, % Baa % 0 2, % Ba % % B % % Total 0 5, % 0 231, % 15 July 2008 Special Comment -

16 US CMBS Similar to the US ABS ex. HEL sector, the US CMBS sector experienced stable performance with only 13 new impairments during 2007 compared with 23 new impairments in 2006 (see Exhibit 19). All of the 2007 impairments were associated with deals that closed in 2002 or earlier, showing that the phenomenon of weak performance of 2006 and 2007 RMBS and HEL vintages has not been evident so far in the US CMBS sector. Exhibit 19: US CMBS Material Impairment Trends Exhibit 19A: Number of Impairments by Impairment Year Principal Impairment 2001 Impairment Year Interest Impairment 2007 Exhibit 19B: Impairments by Closing Year 35 8% 30 7% 25 6% 5% 20 4% 15 3% 10 2% 5 1% 0 0% Closing Year Impairment Count Cum Impairment Rate Exhibit 19C: Trailing 12-Month Impairment Rates by Rating (Aaa, Aa, A) 9.0% 8.0% 7.0% 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Aaa Aa A Dec-05 Dec-07 Exhibit 19D: Trailing 12-Month Impairment Rates by Rating (Baa, SG, All) 20.0% 15.0% 10.0% 5.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Baa SG All Dec-05 Dec July 2008 Special Comment -

17 Global CDOs Similar to the US HEL and RMBS sectors, global CDOs experienced weak performance in 2007 with the 537 new impairments during the year exceeding the sum of all historical impairments in the sector (see Exhibit 20). Of the new impairments, 246 and 291 were associated with principal and interest impairments, respectively, and 87% were associated with 2006 and 2007 vintages. It should be noted that over 96% of the 2007 impairments were SF CDOs and around 2% were from the market value CDO subsector, with only 1% related to corporate CLOs and CBOs. Exhibit 20: Global CDO Material Impairment Trends Exhibit 20A: Number of Impairments by Impairment Year Principal Impairment 2001 Impairment Year Interest Impairment 2007 Exhibit 20B: Impairments by Closing Year % % % % % 0 0% Closing Year Impairment Count Cum Impairment Rate Exhibit 20C: Trailing 12-Month Impairment Rates by Rating (Aaa, Aa, A) 3.5% 3.0% 2.5% 2.0% 1.5% 1.0% 0.5% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Aaa Aa A Dec-05 Dec-07 Exhibit 20D: Trailing 12-Month Impairment Rates by Rating (Baa, SG, All) 20.0% 15.0% 10.0% 5.0% 0.0% Dec-93 Dec-95 Dec-97 Dec-99 Dec-01 Cohort End Month Dec-03 Baa SG All Dec-05 Dec-07 The extent of the poor performance of the SF CDO subsector is evident across the rating categories, with the trailing 12-month impairment rates for global CDOs rising sharply for Aaa, Aa, A and Baa securities as well as for the SG and All ratings categories. The poor performance of SF CDOs is also highlighted in Exhibit 21 which shows that, within the Global CDO sector, the performance of HY CBOs and of SF CDOs has been significantly worse than that of the other subsectors. 17 July 2008 Special Comment -

18 Exhibit 21: Global CDOs Cumulative Impairment Rates by Deal Type 25% 22.1% 20% 15% 10% 10.1% 8.0% 5% 0% 2.3% 3.1% 3.1% 1.3% 0.4% 0.2% 0.5% 0.3% 0.1% 0.3% 0.9% HY CLO Syn Arb BalSh CF MV BalSh Syn SF CDO HY CBO By Count By Volume Indeed, HY CBOs have experienced twice as high a lifetime impairment rate (measured as the total number of impairments over the total lifetime issuance) as the SF CDO sector, the next highest sector. In all cases, the lifetime impairment rate by volume is less than the lifetime impairment rate by count. The impairment performance of the worst performing vintages (2006 and 2007) for the SF CDO subsector is broken out by rating category in Exhibit 22. The impairment performance of the 2006 and 2007 SF CDO vintages has been somewhat comparable, with the former experiencing 3.7% (by dollar volume) and the latter experiencing 5.0% impairment rates to date across all rating categories. The 2006 and 2007 vintages have so far seen Aaa impairment rates on the order of 1% to 3% with Baa impairment rates on the order of 30% to 35%. Exhibit 22: Impairments among SF CDOs Issued in 2006 and 2007 SF CDOs 2006 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa % 2, , % Aa % , % A % 1,591 8, % Baa % 2,152 6, % Ba % 583 1, % B % % Total 255 1, % 8, , % SF CDOs 2007 Vintage By Number of Tranches By Dollar Volume (US $MM) Original Rating Impaired Rated % Impaired Impaired Rated % Impaired Aaa % 4, , % Aa % 1,013 12, % A % 1,590 6, % Baa % 1,590 5, % Ba % % B 0 0 NA 0 0 NA Total 201 1, % 8, , % 18 July 2008 Special Comment -

19 Loss-Given-Default on Principal-Impaired Tranches and Historical Average Loss Rates This section presents analysis of loss severity rates, also known as loss-given-default (LGD) rates, and combines information on loss severity rates with data on material impairment rates to derive cumulative loss rates. Estimating expected final LGD on impaired structured finance securities is particularly challenging because most securitizations are structured as pass-through securities and market prices are rarely available for structured securities in default. In previous research, we developed models to estimate final LGD for impaired tranches backed by residential mortgage collateral and for impaired collateralized bond obligations. In 2006, we developed a final LGD projection model for impaired manufactured housing ABS securities. 7 In this report we update all these projections and derive estimated aggregate loss rates by sector and by rating. Moody s regularly updates the payment and loss records of impaired structured finance securities. For each tranche, we are able to calculate the present value of losses (to date) using the coupon rate as the discount rate. For many tranches, the loss rate to date is effectively the final loss severity because their balances have been written down to zero (called resolved impairments in this report). Many impaired tranches, however, have positive balances outstanding at the end of the study period and potential sources of future cash distributions to investors; hence, their expected final loss severity rates need to be estimated. Although the majority of impaired structured securities are currently principal impaired, some are only experiencing interest shortfalls. Due to the higher probability of cure for interest-only impaired securities than principal impaired securities, and the greater challenge of forecasting losses for interest impaired tranches, in this report we will calculate and provide loss severity rates only for principal impairments. LGD for All Resolved Impairments We first examine LGD for the 789 total impairments on which we have final, resolved impairment data. Recall that resolved impairments are defined as those impairments on which the principal balances were written down to zero and the final losses known by the end of We categorize the remaining 2,518 as unresolved impairments and deal with the estimation of LGD on those securities in subsequent sections. Exhibit 23 contains mean and median LGD, stratified by broad rating category, as well as for the broader investment grade and speculative grade categories. 8 Additionally, final LGD rates are computed by both original rating and rating at impairment, using the original balance and balance at impairment, respectively. Exhibit 23: Realized Final LGD Rates by Rating for All Resolved Principal Impairments in the All Structured Finance Category, By Original Rating (% of original balance) By Rating at Impairment (% of impairment-date balance) Rating Counts Mean Median Std Dev Rating Counts Mean Median Std Dev Aaa 8 2.7% 3.0% 1.0% Aaa % 20.1% 0.0% Aa % 16.8% 34.2% Aa 1 2.8% 2.8% NA A % 79.5% 29.2% A % 99.6% 34.1% Baa % 77.7% 30.0% Baa % 99.4% 29.3% Ba % 86.3% 28.5% Ba % 99.1% 27.0% B % 69.4% 25.5% B % 98.3% 28.9% Caa % 75.2% 6.0% Caa % 98.6% 24.1% Investment Grade % 76.7% 31.7% Investment Grade % 99.4% 31.0% Speculative Grade % 82.1% 28.0% Speculative Grade % 98.7% 26.9% All Ratings % 79.2% 30.2% All Ratings % 98.9% 27.8% 7 8 See Moody s Special Comment, Measuring Loss-Given-Default for Structured Finance Securities: An Update, December Compared to the 2006 Default and Loss Study, the number of realized final LGD rates for all resolved principal impairments in Exhibit 23 is based on a smaller sample. The reason for this is a stricter definition of what constitutes a final or resolved LGD rate in the 2007 study. Therefore, some impairments that were included in last year s study were excluded this year as they did not meet the new, stricter definition of a resolved impairment. 19 July 2008 Special Comment -

20 On average, the present value of losses at origination for all resolved principal impaired securities jumped to 66% this year, up from the 54% LGD rate reported in the 2006 study. Similarly, the LGD rate measured as the present value of losses as a percent of impairment-date balance is up to 86% from 73% last year. LGD rates are not monotonic in rating, and the differences between the investment grade LGD and speculative grade LGD rates are small, particularly when measured by rating at impairment. Nearly all measured LGD rates are skewed, with median LGD rates at impairment nearing 100% for all rating classes below Aa. LGD rates vary much more widely across sectors than by rating class, and Exhibit 24 contains mean LGD rates for broad asset classes and some sub-asset classes. In virtually all cases, LGD rates for securities originally rated investment grade are lower than their speculative grade counterparts within the same sector (and even subsector). Exhibit 24: Realized Final LGD Rates by Sector for All Resolved Principal Impairments, Investment Grade at Origination Speculative Grade at Origination Asset Class Counts Mean Counts Mean US ABS ex. HEL % % ABS - Automobiles - Subprime % 1 2.0% ABS - Credit Card - Bank % % ABS - Franchise Loans % % ABS - Leases - Aircraft % 0 NA ABS - Leases - Equipment 0 NA % ABS - Manufactured Housing - Term % % ABS - Mutual Fund Fees % % Global CDOs % % CDO - Emerging Markets % 0 NA HY CBO % % HY CLO 4 8.8% 0 NA SF CDO 0 NA 1 5.7% US CMBS % % US RMBS/HEL % % Alt-A % % HELOC % % Jumbo 3 2.9% % Subprime Firsts % % Subprime Seconds % % Scratch & Dent/Nonperforming/ Reperforming % % Other % % Compared to the previous study, US ABS ex. HEL and US CMBS LGD rates have remained quite stable, as have Global CDO LGDs. Given the jump in Global CDO impairments in 2007, this might be surprising, but we are considering only resolved principal impairments in the exhibit above, and principal balances on the recently-impaired securities likely have not fully been written down yet. The US RMBS/HEL sector is further broken-out into sub-categories, and tranches backed by HELOCs and subprime seconds have fared particularly poorly. Indeed, LGD rates for both are near or above 90%, well 20 July 2008 Special Comment -

21 above the LGD rates for other US housing sub-sectors. There is generally significant differentiation between LGD rates for securities originally rated investment grade and securities originally rated speculative grade, with originally-rated investment grade securities experiencing lower LGD rates. The two exceptions are again the HELOC and subprime seconds categories, which experienced high LGD rates across all ratings. LGD for Principal Impaired RMBS/HEL Tranches Exhibit 25 contains the estimated LGD rates for a combined sample of resolved and unresolved US RMBS and HEL securities that have experienced principal impairments. There are 831 principal impairments in this larger sample, up from 545 resolved principal impairments. LGD rates remained low for securities originally rated Aaa and Aa, and originally speculative grade ratedsecurities suffered a 13% higher LGD rate than investment grade securities. LGD rates measured as a percent of the impairment-date balance are higher than LGD rates measured as a percent of original balance, owing mainly to discounting and principal amortization. Median impairment date-based LGD rates were above 90% for all ratings below Aa, and for the broader investment and speculative grade sectors as well. Exhibit 25: Estimated LGD Rates by Rating for a Combined Sample of Resolved and Unresolved RMBS/HEL Principal Impairments, By Original Rating (% of original balance) By Rating at Impairment (% of impairment date balance) Rating Counts Mean Median Std Dev Rating Counts Mean Median Std Dev Aaa 8 2.8% 3.2% 1.0% Aaa 0 NA NA NA Aa % 21.8% 39.8% Aa % 29.7% 38.0% A % 90.9% 32.3% A % 99.6% 36.2% Baa % 74.9% 37.3% Baa % 99.5% 34.1% Ba % 87.1% 27.9% Ba % 99.0% 27.8% B % 64.4% 27.9% B % 98.0% 29.0% Caa 0 NA NA NA Caa % 93.4% 30.1% Investment Grade % 84.6% 37.5% Investment Grade % 99.5% 34.7% Speculative Grade % 85.1% 28.7% Speculative Grade % 98.1% 29.1% All Ratings % 85.0% 35.1% All Ratings % 98.6% 30.3% LGD for Principal Impaired CDO Tranches Moody s developed and published a model to project final LGD rates for unresolved high-yield CBOs in 2005, and in this section, we apply this model to all unresolved principal impaired cash CDOs and append the forecasted LGD rates to the sample of resolved CDO LGD rate data, which includes resolved synthetics. 9 Exhibit 26 summarizes the results. 9 See Default & Loss Rates of U.S. CDOs: , Moody s Special Comment, March The model uses the weighted average rating factor (WARF) and the weighted average maturity (WAM), as reported by Moody s deal performance reports, to find the weighted average loss rates expected in the pool. These expected pool loss rates are used to adjust the 2006 year-end OC ratios, after taking into account the potential excess interest that would become available in the deal, if any excess exists. The adjusted OC ratios are then used to derive future payments available to the impaired tranches and compute the tranches projected loss rates. 21 July 2008 Special Comment -

22 Exhibit 26: Estimated LGD Rates by Rating for a Combined Sample of Resolved and Unresolved CDO Principal Impairments, By Original Rating (% of original balance) By Rating at Impairment (% of impairment date balance) Rating Counts Mean Median Std Dev Rating Counts Mean Median Std Dev Aaa % 87.1% 49.3% Aaa % 60.0% 46.2% Aa % 72.8% 40.7% Aa % 100.0% 3.8% A % 92.8% 24.0% A % 100.0% 4.3% Baa % 68.0% 25.5% Baa % 98.5% 22.2% Ba % 68.8% 21.7% Ba % 99.8% 25.6% B % 64.6% 23.5% B % 99.5% 31.0% Caa 0 NA NA NA Caa % 100.0% 28.7% Investment Grade % 68.9% 28.5% Investment Grade % 100.0% 22.0% Speculative Grade % 65.7% 22.2% Speculative Grade % 100.0% 28.7% All Ratings % 68.4% 26.7% All Ratings % 100.0% 26.6% Average LGD rates by impairment date balance were generally much higher than their original balance counterparts, owing mainly to discounting and principal amortization. Loss severity at impairment was above 80% for all rating categories, excluding Aaa. As with other asset classes, median loss severities exceed mean loss severities, with median severities at impairment date balance at or near 100% for all categories except Aaa. LGD for Principal Impaired MH Tranches Moody s introduced an LGD projection model for impaired ABS securities backed by manufactured housing (MH) loans in 2006, and Exhibit 27 contains descriptive LGD rate statistics computed using actual LGDs from resolved MH principal impairments and predicted LGDs from unresolved MH principal impairments. 10 Exhibit 27: Estimated LGD Rates by Rating for a Combined Sample of Resolved and Unresolved MH Principal Impairments, By Original Rating (% of original balance) By Rating at Impairment (% of impairment date balance) Rating Counts Mean Median Std Dev Rating Counts Mean Median Std Dev Aaa 0 NA NA NA Aaa 0 NA NA NA Aa % 44.1% 15.4% Aa % 86.6% 17.1% A % 66.0% 10.9% A % 60.2% 22.7% Baa % 53.4% 21.4% Baa % 95.2% 25.0% Ba % 78.8% 17.6% Ba % 95.3% 21.0% B % 80.6% 0.1% B % 84.9% 23.2% Caa 0 NA NA NA Caa % 85.4% 13.6% Investment Grade % 56.2% 19.5% Investment Grade % 91.8% 24.8% Speculative Grade % 79.7% 17.2% Speculative Grade % 92.2% 20.3% All Ratings % 61.7% 20.5% All Ratings % 92.2% 21.5% 10 See Moody s Special Comment, Measuring Loss-Given-Default for Structured Finance Securities: An Update, December July 2008 Special Comment -

23 The average LGD rate, computed as a percent of original balance, for all MH principal impairments is 58%, with significant variation between the investment grade LGD rate of 54% and the speculative grade LGD rate of 73%. The MH LGD rate distribution is less skewed than the LGD rate distributions in other asset classes as the median and mean are close. Loss severity as a percent of impairment date balance is greater than original balance loss severity nearly across the board, with median severities at impairment date above 95% for Baa and Ba tranches. Historical Average Multi-Year Loss Rates Multi-year cumulative loss rates are the weighted average of marginal loss rates, which we compute using marginal principal impairment and LGD rates. As in previous studies, we use sector specific LGD and impairment rates to calculate cumulative loss rates, except for the US CMBS sector, which again uses a combined sample of RMBS, HEL, and CMBS securities. 11 Loss rates in the all structured finance category, as in the 2006 study, use marginal impairment rates based on all impaired securities, rather than a weighted average of RMBS/HEL and CDOs, as was done prior to the 2006 study. Exhibit 28 shows five-year cumulative loss rates by both original and cohort rating. Detailed multi-year cumulative loss rates by rating, horizon, and sector appear in Appendix 5. Exhibit 28: Structured Finance Five-Year Cumulative Loss Rates by Rating, % 10% 8% 6% 4% 2% 0% Aaa Aa A Baa SG Original Rating Cohort Rating Although not visible in the above chart, Aaa-rated tranches, both by original rating and cohort rating, experience five-year cumulative loss rates of 3bp. From Exhibit 28, we note the following: Estimated cumulative loss rates increase as rating falls Unlike in prior years studies, five-year cumulative loss rates for securities originally rated A or Baa are higher than if measured by cohort rating. Speculative-grade five-year cumulative loss rates are higher when measured by cohort rating as opposed to original rating. One of the main reasons is the momentum effect, which says that a downgraded security has a higher probability of being downgraded again and/or default than a security that has the same rating but has never been downgraded, and vice versa for upgrades. 11 The US CMBS sector has low historical principal impairment rates, especially for longer horizons. As such, the US CMBS loss severity dataset is quite small. Therefore we have used loss severity data from other mortgage related sectors (e.g. US RMBS/HEL) as guidance to estimate US CMBS LGD rates. 23 July 2008 Special Comment -

24 Appendix I: Description of Data Sample and Glossary The data sample used in this report includes all public, 144A, and private tranches with a publishable Moody s long-term global debt rating among global asset-backed securities (ABS), commercial and residential mortgage-backed securities (CMBS and RMBS), collateralized debt obligations (CDOs), and other structured finance, including asset backed commercial paper (ABCP), structured investment vehicles (SIVs), structured covered bonds, catastrophe bonds, and derivative product companies. Provisional ratings, credit estimates or evaluations, short-term ratings, and national scale ratings are not included. The following types of securities are excluded from the definition of global structured finance and therefore are not included in the data sample: repackaged securities, structured notes, and other credit derivatives which are basically pass-throughs of the rating of another entity. This data set is an expansion of the data set that was used in prior structured finance default and loss studies. 12 Unlike the data set from previous years, this data sample: Includes tranches wrapped by financial guarantors, government agencies, and government sponsored enterprises (GSEs); Includes interest-only (IO) and residual tranches; Includes some transactions outside of the four major sectors (ABS, CDO, CMBS, RMBS) of structured finance, such as ABCP, SIVs, structured covered bonds, catastrophe bonds and derivative product companies; Does not collapse tranches with the same rating from the same deal, i.e. all pari-passu tranches are counted in the data sample. The exceptions to this are notes with the same rating issued out of the same program for ABCP, SIVs and structured covered bonds, in which case only the rating of the program and not each individual security is counted. The data used to create this report are commercially available via Moody's Structured Finance Default Risk service and Moody s Corporate Default Risk service. For more information, please DefaultResearch@moodys.com. Glossary Material Impairment Structured finance securities are defined as being in material impairment if they have: Sustained a payment shortfall that remained uncured, or Been downgraded to Ca or C. Prepayment-related and AFC-related interest shortfalls are not considered to be material impairments, but PIKing tranches are. Explicit principal write-downs are included whereas implicit principal write-downs or under-collateralizations are not. The impairment status of a security may change as it goes from cured (i.e. all outstanding shortfalls and losses were repaid in full) to uncured (i.e. positive interest shortfalls or principal losses outstanding), or vice versa. If any securities rated Ca or C but not in payment shortfall are upgraded, they are considered to be no longer in material impairment. Securities rated Ca or C that were not upgraded are in material impairment even if their payment shortfalls have been cured. Finally, securities with very minor shortfalls or losses are excluded. 12 The expanded data sample was first introduced in our 2007 rating transitions studies that were published this year. The data sample in this study was extracted following similar guidelines. 24 July 2008 Special Comment -