Credit Opinion: Credit Suisse International

Similar documents
Credit Suisse International

Credit Suisse International

OECD Workshop on Data Collection

Rating Action: Moody's assigns Counterparty Risk Rating to FCA Bank

Policy for Designating and Assigning Unsolicited Credit Ratings

Credit Opinion: ING Groep N.V.

State Outlook: Debt Affordability. NCSL Conference Gail Sussman, Managing Director

Rating Action: Moody's affirms Baa3 senior unsecured debt ratings of ICICI Bank's Bahrain branch Global Credit Research - 17 Aug 2017

Rating Action: Moody's upgrades Permanent tsb's deposit and senior unsecured ratings; outlook stable Global Credit Research - 08 May 2015

Credit Opinion: Banca Sella Holding

Rating Action: Moody's changes outlook of Central Bank of India and Indian Overseas Bank to positive from stable

Rating Action: Moody's assigns definitive ratings to Lloyds' non-ring-fenced banks LBCM and LBIL

Policy for Designating and Assigning Unsolicited Credit Ratings in the European Union

Credit Opinion: EBS Ltd

Standalone BCA upgraded to b1 from b3 for Ulster Bank Limited and to b2 from b3 for Ulster Bank Ireland Limited

Rating Action: Moody's upgrades BAWAG's ratings to A2; outlook positive

Mongolian Banking System

Rating Action: Moody's Upgrades the City of Sacramento, CA's Lease Revenue Bonds to A1; Confirms Ser and Ser. 1993A at A2; outlook is stable

Credit Opinion: Federal Home Loan Bank of New York

Rating Action: Moody's assigns Counterparty Risk Ratings to three Sri Lankan banks 18 Jun 2018

Rating Action: Moody's changes the outlook on FCA Bank's senior debt rating to positive from stable

Rating Action: Moody's downgrades Lowe's unsecured ratings to Baa1; P-2 commercial paper rating affirmed 12 Dec 2018

blend Funding plc Update to credit analysis Credit strengths » Liquidity reserve as structural enhancement Credit challenges

Rating Action: Moody's changes outlook on Bank Zachodni WBK S.A.'s ratings to positive Global Credit Research - 29 Jan 2018

Rating Action: Moody's upgrades Kommunalkredit Austria AG's public-sector covered bonds Global Credit Research - 25 Jul 2017

Rating Action: Moody's Changes Sparebanken Vest's Rating Outlook to Stable From Negative

Rating Action: Moody's upgrades the ratings of Philippine National Bank and Rizal Commercial Bank Global Credit Research - 23 Nov 2017

Global Credit Research - 19 Apr 2018

Rating Action: Moody's confirms ratings of six financial institutions in Kazakhstan; concludes review

Rating Action: Moody's assigns (P)A1 senior unsecured rating to SpareBank 1 Ostlandet's jointly-owned EMTN program

Rating Action: Moody's downgrades senior unsecured debt instruments of 14 German banks following change in bank insolvency law

Rating Action: Moody's assigns Counterparty Risk Ratings to 14 Austrian banks

Credit Opinion: Federal Home Loan Banks

Rating Action: Moody's affirms BIL's A2 senior unsecured rating and changes outlook to stable 07 May 2018

Rating Action: Moody's affirms 22 German banks' senior unsecured debt ratings; changes 16 outlooks to negative

Rating Action: Moody's downgrades the ratings of The Royal Bank of Scotland plc and upgrades the ratings of National Westminster Bank Plc.

Policy on the "SEC Rule 17g-7 of Representation and Warranties" (R&Ws)

Rating Action: Moody's downgrades Banca Carige S.p.A. and places ratings under review for downgrade 07 Aug 2018

Rating Action: Moody's upgrades several Irish mortgage covered bond ratings; actions conclude review

Rating Action: Moody's reviews NORD/LB Luxembourg S.A. - Public-Sector Covered Bonds, direction uncertain 19 Dec 2018

Rating Action: Moody's downgrades ENGIE to A2; stable outlook Global Credit Research - 27 Apr 2016

Rating Action: Moody's upgrades Bank of Ireland and changes Bank of Ireland UK's outlook to positive

CPPIB Capital Inc. Semiannual Update. Credit Strengths. Credit Challenges. Rating Outlook The rating outlook is stable.

Rating Action: Moody's reviews Depfa ACS Bank's public sector covered bonds for downgrade Global Credit Research - 14 Sep 2016

Rating Action: Moody's assigns Aa3 to West Virginia SBA's $44.4M Capital Improvement Ref. Rev. Bonds, Ser Global Credit Research - 08 Sep 2017

Rating Action: Moody's upgrades DVB Bank's debt to Aa3 from Baa1 and deposits to Aa1 from A2

Credit Opinion: CorpBanca

Rating Action: Moody's affirms Berner Kantonalbank's Aa1 deposit and A1 senior unsecured debt ratings

Rating Action: Moody's affirms Volvofinans Bank's A3 rating; stable outlook 26 Feb 2019

Rating Action: Moody's affirms Intrum Justitia's Ba2 corporate family rating; outlook changed to stable Global Credit Research - 19 Apr 2018

Ag Lending Experience of Living Through the Cycles

Siauliu Bankas, AB. Siauliu Bankas capital metrics will strengthen with EBRD s debt-to-equity conversion. ISSUER COMMENT 13 August 2018

Agenda. New Mexico School District Bond Ratings 9/8/17

Rating Action: Moody's places debt and long-term deposit ratings of Credit Europe Bank N.V. on review for upgrade

Rating Action: Moody's upgrades NORD/LB's Fuerstenberg preference shares to Caa1(hyb) Global Credit Research - 18 Apr 2018

Regional Economic Outlook

Roselle Park Borough, NJ

Policy on Conflict of Interest Certification

Federal Home Loan Bank of Des Moines

Rating Action: Moody's confirms Promsvyazbank's ratings at B2; developing outlook

Policy for Analyst Rotation

Snohomish County Public Utility District 1

business cultures. LIQUIDITY PROFILE Moody's considers Lafarge's liquidity profile on a stand-alone basis to be good for the next 12 months, largely

Rating Action: Moody's affirms Aaa IFS rating of New York Life; stable outlook Global Credit Research - 27 Jul 2017

Federal Home Loan Bank of Boston

Rating Action: Moody's affirms HSH Nordbank's Baa3/Prime-3 debt and deposit ratings

Rating Action: Moody's confirms Banco Popolare's Ba3 deposit and senior debt rating; outlook stable

Challenging Issues and Alternative Approaches to CRE Credit Risk Modeling. RPC Conference, Scottsdale

Rating Action: Moody's takes rating actions on Irish mortgage covered bonds Global Credit Research - 26 Sep 2016

Rating Action: Moody's upgrades mortgage covered bonds issued by AIB Mortgage Bank and EBS Mortgage Finance Global Credit Research - 29 Nov 2016

Rating Action: Moody's assigns A2 to 2016B & C Senior Bonds of Central Florida Expressway Auth. (CFX), FL; Outlook positive

Rating Action: Moody's downgrades the ratings of four Italian utilities 23 Oct 2018

Rating Action: Moody's downgrades South Carolina Public Service Authority revenue bonds; rating outlook negative

Rating Action: Moody's upgrades Belfius Bank's senior unsecured and deposit ratings to A2 with a positive outlook

Rating Action: Moody's reviews covered bonds issued by Hypo NOE, Hypo Tirol and Heta AR for upgrade Global Credit Research - 25 May 2016

Rating Action: Moody's affirms Banco Sabadell's ratings, outlook changed to stable from positive 19 Sep 2018

Rating Action: Moody's affirms Aa1 issuer and bond ratings of the International Finance Facility for Immunisation (IFFIm) with a stable outlook

Rating Action: Moody's concludes review on SC Citadele Banka and Siauliu Bankas

Rating Action: Moody's assigns Aa3 to Trinity Health Credit Group's (MI) Ser bonds; outlook revised to stable

Federal Home Loan Bank of Des Moines

Rating Action: Moody's downgrades long-term deposit and senior unsecured debt ratings of Danske Bank to A2 and maintains a negative outlook

Rating Action: Moody's upgrades PGW (PA) to A3 from Baa1; Assigns A3 to $278.2 mil Gas Works Rev. Refunding Bds., 15th Series

Town of Easton, MA. Credit Strengths. Manageable long-term liabilities. Credit Challenges. Reliance on reserves to address budget gaps

Rating Action: Moody's upgrade Equinor's rating to Aa2 and BCA to a1; stable outlook 09 Aug 2018

Rating Action: Moody's upgrades Lufthansa to Baa3; stable outlook Global Credit Research - 24 Aug 2017

Rating Action: Moody's announces rating actions on student loan ABS backed by FFELP student loans following the update of its rating methodology

Rating Action: Moody's upgrades deposit ratings of Landesbank Berlin and Berlin Hyp to Aa2, changes outlook to stable

Volusia County School District (FL)

Rating Action: Moody's assigns Caa3 Issuer Rating to US Virgin Islands; lowers ratings on four liens of Matching Fund Revenue Bonds

ABN AMRO Bank N.V. Q1 2018: Higher impairment offset revenue growth. ISSUER COMMENT 16 May Summary opinion

Rating Action: Moody's changes outlooks on ratings of 14 Russian financial institutions to stable from negative

Credit Opinion: Electrabel SA

PSP Capital Inc. Update to credit analysis. CREDIT OPINION 27 August Update

Rating Action: Moody's changes outlook on Telekom Austria's ratings to positive Global Credit Research - 05 Jul 2017

Rating Action: Moody's assigns A1 to UConn GO bonds supported by State of Connecticut; outlook stable Global Credit Research - 29 Mar 2018

Rating Action: Moody's changes outlook to positive on Orkuveita Reykjavikur's Ba2 rating Global Credit Research - 15 Jun 2017

Credit Opinion: Municipal Guarantee Board

Credit Opinion: Denizbank A.S.

Rating Action: Moody's changes outlook to positive on all ratings of Allied Irish Banks and assigns (P) Ba2 rating to holding company senior programme

Rating Action: Moody's changes the outlook to negative on three Infrastructure Issuers operating in Colombia

Transcription:

Credit Opinion: Credit Suisse International Global Credit Research - 31 Mar 2015 London, United Kingdom Ratings Category Bkd Bank Deposits Issuer Rating Senior Unsecured Jr Subordinate -Dom Curr Ult Parent: Credit Suisse Group AG Senior Unsecured MTN Subordinate MTN Jr Subordinate MTN Parent: Credit Suisse AG Bank Deposits Baseline Credit Assessment Adjusted Baseline Credit Assessment Issuer Rating Senior Unsecured Subordinate -Dom Curr Jr Subordinate MTN Commercial Paper Other Short Term Moody's Rating *A1/P-1 Baa3 (hyb) **(P)A2 ***(P)Baa3 (P)Ba1 *A1/P-1 baa1 baa1 Baa2 (P)Baa3 **P-1 **(P)P-1 * Rating(s) within this class was/were placed on review on March 17, 2015 ** Placed under review for possible downgrade on March 17, 2015 *** Placed under review for possible upgrade on March 17, 2015 Contacts Analyst Phone David Fanger/New York City 1.212.553.1653 Alessandro Roccati/London 44.20.7772.5454 Robert Young/New York City 1.212.553.1653 Opinion SUMMARY RATING RATIONALE Credit Suisse International (CSI), formerly Credit Suisse First Boston International, is a UK-domiciled bank specializing mainly in OTC derivatives trading and market making. CSI is the principal risk taker for derivatives within the Credit Suisse Group. As such, it is a fully integral part of Credit Suisse's operations. The bank is owned

80% by Credit Suisse AG and 20% by Credit Suisse Group AG (the parent holding company of Credit Suisse AG). CSI is an unlimited liability company and, as such, its shareholders have a joint, several and unlimited obligation to meet any insufficiency in the assets of CSI in the event of its liquidation. This obligation does not constitute a direct guarantee by Credit Suisse of CSI's liabilities, and prior to any liquidation of CSI, creditors of CSI have no legal recourse to Credit Suisse AG or Credit Suisse Group AG. However, we believe that the unlimited liability, as well as the operational importance of CSI to Credit Suisse, provide a very strong incentive for Credit Suisse to service the obligations of CSI as if they were direct obligations of Credit Suisse AG. Based upon these factors, Moody's rates the debt of CSI at the same level as those direct obligations of Credit Suisse AG with a similar priority of claim. On 17 March 2015, we placed the A1 long-term deposit rating of Credit Suisse AG on review for upgrade. Concurrently we placed its A1 long-term issuer and senior unsecured debt ratings on review for downgrade. The rating action reflects the reduced likelihood of government support for senior creditors in Switzerland as well as the introduction of our new bank rating methodology and specifically our advanced Loss Given Failure (LGF) approach to rating different classes of bank obligations based upon loss severity. Credit Suisse AG's junior instruments were not affected by the action. The deposit, issuer, and senior unsecured debt ratings of CSI, which are rated at the same level as those of Credit Suisse AG based on the unlimited liability of its shareholder Credit Suisse AG, was also placed on review (A1 deposit rating on review for upgrade, A1 issuer and senior debt ratings on review for downgrade). CSI's junior instruments were not affected by the action. For a detailed discussion of the rating rationale for Credit Suisse AG, please see Moody's published research on Credit Suisse AG and Credit Suisse Group AG. Rating The review on CSI's deposit and senior unsecured debt ratings was triggered by the introduction of our new methodology, and specifically our advanced Loss Given Failure analysis that applies to Credit Suisse AG given that it is subject to an Operational Resolution Regime under the Swiss bank resolution framework. The review will also take into account the evolution of the Swiss bank resolution regime and the accelerating global trend towards the use of burden-sharing tools with creditors (i.e. bail-in) to resolve failing banks. In particular, we consider that, with the Swiss resolution regime being largely adopted, the likelihood of support for senior creditors from the Swiss government in the event of need is diminished. We also believe that the efforts on making the larger Swiss banks resolvable by issuing debt out of holding company structures and creating a Swiss banking subsidiary are important steps in overcoming the main obstacles to their resolvability, namely their global reach and their complex interconnection with other parts of the financial system. These factors have resulted in greater likelihood that creditors will be bailed in and have prompted us to reconsider the systemic support assumptions that we factor into our credit ratings of Swiss banks. As obligations which benefit from an unlimited liability of Credit Suisse AG to meet any insufficiency in the assets of CSI in the event of its liquidation, we believe the rated debt obligations of CSI are similarly exposed to such developments. The review on Credit Suisse AG's deposit and senior unsecured debt will focus on the amount and permanence of senior long-term debt outstanding at Credit Suisse AG and its branches as well as the amount of debt subordinated to it, including senior debt at the parent holding company Credit Suisse Group AG. Based on our initial LGF analysis, we expect Credit Suisse AG's deposits to be upgraded by one notch, reflecting our expectations for three notches of uplift from the BCA due to an extremely low loss-given-failure for Credit Suisse AG junior deposits given Swiss depositor preference, plus one notch of uplift due to a moderate likelihood of government support. Given the smaller amount of subordination protecting senior creditors (as compared to depositors), our initial LGF analysis indicates a potential downgrade of one notch for bank-level senior debt at Credit Suisse AG, reflecting our expectations for one notch of uplift from the BCA due low loss-given-failure plus one notch of uplift due to moderate government support. Since Moody's ratings for CSI are based on the unlimited liability of Credit Suisse AG for the liabilities of CSI and the close linkages between CSI and Credit Suisse AG, we believe a similar outcome is likely for the deposit and senior unsecured debt ratings of CSI. Recent Developments

In November 2013, Credit Suisse unveiled a plan that would modify its legal entity structure in connection with efforts to simplify its operating infrastructure and address existing and anticipated regulatory requirements for global recovery and resolution planning by systemically important banks such as Credit Suisse. As a part of this plan, Credit Suisse would consolidate its two principal UK operating subsidiaries - CSI and Credit Suisse Securities Europe Limited (CSSEL) - into a single subsidiary which would be the hub of the bank's European investment banking business. Another part of the plan would transfer the bank's US derivatives business, which is currently booked in CSI or CSSEL, to the bank's existing US broker-dealer. The implementation of the full program, which has already been approved by the Board of Directors of the Group but is subject to regulatory approval, is planned from mid-2015. The prospects for a limited reduction in the Group's consolidated regulatory capital requirements, provided for under Swiss banking law if Credit Suisse's resolvability is improved, is one main driver underpinning the changes. Also, we believe that the increasing emphasis of the UK bank regulator (the Prudential Regulation Authority) on the "self-sufficiency" (ie. adequate capital and liquidity resources) of UK affiliates of foreign banks is another factor driving the changes. We believe it is too soon to assess the potential impact of these proposed changes on the issuer ratings of CSI. Key considerations will be which subsidiary is the surviving entity following the merger as well as the legal structure of that entity and the extent to which its shareholders will continue to have a joint, several and unlimited obligation to meet any insufficiency in the assets of the entity in the event of its liquidation as they currently do with CSI. This publication does not announce a credit rating action. For any credit ratings referenced in this publication, please see the ratings tab on the issuer/entity page on http://www.moodys.com for the most updated credit rating action information and rating history. 2015 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 CREDIT RATINGS AND RESEARCH PUBLICATIONS PUBLISHED BY MOODY S ( 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. 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. MOODY S CREDIT RATINGS AND MOODY S PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS FOR RETAIL INVESTORS TO CONSIDER MOODY S CREDIT RATINGS OR MOODY S PUBLICATIONS IN MAKING ANY INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY S PRIOR WRITTEN CONSENT. All information contained herein is obtained by MOODY S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided AS IS without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY S is not an auditor and cannot in every instance independently verify or validate information received in the rating process or in preparing the Moody s Publications. To the extent permitted by law, MOODY S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY S. To the extent permitted by law, MOODY S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information. NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY S IN ANY FORM OR MANNER WHATSOEVER. Moody s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody s Corporation ( MCO ), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody s Investors Service, Inc. have, prior to assignment of any rating, agreed to pay to Moody s Investors Service, Inc. for appraisal and rating services rendered by it fees ranging from $1,500 to approximately $2,500,000. 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. 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 clients. It would be dangerous for retail clients to make any investment decision based on MOODY S credit rating. If in doubt you should contact your financial or other professional adviser. For Japan only: MOODY'S Japan K.K. ( MJKK ) is a wholly-owned credit rating agency subsidiary of MOODY'S

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 appraisal and rating services rendered by it fees ranging from JPY200,000 to approximately JPY350,000,000. MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.