Rating Action: Moody’s assigns provisional rating to SAIC-GMAC’s first auto loan ABS transaction for 2022Global Credit Research – 29 Dec 2021RMB9,430 million of securities to be ratedHong Kong, December 29, 2021 — Moody’s Investors Service has assigned provisional ratings to the Class A1, Class A2 and Class B Notes to be issued by Rongteng 2022-1 Retail Auto Loan Securitization, a domestic transaction backed by a pool of auto loans to be originated by SAIC-GMAC Automotive Finance Company Limited (SAIC-GMAC) in China.The complete rating action is as follows:Issuer: Rongteng 2022-1 Retail Auto Loan Securitization….RMB[4,000]M Class A1 Notes, Assigned (P)Aa1 (sf)….RMB[4,700]M Class A2 Notes, Assigned (P)Aa1 (sf).RMB[730]M Class B Notes, Assigned (P)Aa1 (sf)The RMB[570]M Subordinated Notes are not rated by Moody’s.RATINGS RATIONALEWhen assigning the rating, Moody’s analysis focused, among other factors, on (1) the characteristics of the securitized pool; (2) the macroeconomic environment; (3) the lack of historical performance data during the economically distressed period; (4) the parental support available to the servicer; (5) the financial disruption risk in the transaction, which refer to the risk of issuer’s cash flow disruption in case of a servicer termination event, and the mitigants to support timely payments on the Class A1, A2 and B Notes (collectively, “the senior notes”); (6) the protection provided by credit enhancement against defaults and arrears in the securitized pool; and (7) the legal and structural integrity of the transaction.The rating assigned to Class A1 and A2 Notes are constrained by the financial disruption risk in this transaction which involves the assessment of (1) the likelihood that the servicer will be able to continue operations during the life of the transaction, (2) the ease of transfer of responsibilities from the servicer in case it needs to be replaced, and (3) the effectiveness of the mitigants, if any, to mitigate the risk of cash flow disruption caused by the financial distress of the servicer. Moody’s views the financial disruption risk for this transaction as not fully mitigated because of the absence of prefunded reserve fund and the operational risk embedded in the transaction. Upon a servicer termination event, cash flow disruption could result in insufficient collections to pay interest on the Class A1 and A2 Notes, which would trigger an event of default. Due to the limited financial disruption risk, the maximum achievable rating for Class A1 and A2 Notes are at Aa1 (sf).Moody’s considered, among other things, the transaction’s key strengths:(1) Diversified collateral pool composition: The cut-off portfolio consists of 178,957 obligors’ loans with a good level of geographic diversification across 31 regions in China. Typically, a more granular pool exhibits less volatile performance.(2) Favorable pool characteristics: The pool only includes loans to purchase new vehicles. 100{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} of the payments are made via direct debit. All loans are amortizing and have a weighted average LTV of 71.91{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} at origination. The collateral pool has a short weighted average remaining tenor of 29.64 months.(3) Full turbo structure: Subordination of the Senior Notes will increase over time after closing and certain excess spread will be received during the transaction period. The issuer will apply the loan interest and principal repayments in accordance with its priority of payment, including repaying the Class A1 Notes up to its scheduled principal payment on each note’s payment date. The remaining collection will be used to repay the Class A2 Notes until they are repaid in full, and subsequently, and any further remaining collections will be used to sequentially repay the Class A1 and B Notes until they are repaid in full.(4) The originator’s experience in the China auto finance sector: The originator was the first auto finance company established in the China, and has refined its underwriting process over time. The underwriting system is independent from its sales function and dealers. The originator uses a comprehensive set of data to assess a borrower’s creditworthiness. SAIC-GMAC uses its own credit scoring system to assign a credit score to each borrower. Borrowers with score below a floor level are automatically rejected. The originator has a network of dealers which it also has wholesale business relationships with, this allows closer monitoring of the dealers and may allow more consistent origination and quality control.Moody’s has also considered the following weaknesses and mitigants:(1) Untested back-up servicing arrangement: No back-up servicing arrangement will be set up at closing. Servicing of the transaction may be subject to disruption if the originator/servicer fails to perform when needed. Any disruption may result in a significant impact because the transaction has more than 178,000 obligors located in various parts of China. There is no precedent in China of actual servicing transfers to date, although potential replacement servicers exist because there are several captive finance originators with obligors across the country. Moody’s considers the high likelihood of parental support for the servicer and the short weighted average life of the rated notes as key mitigants to this weakness. Although there is no explicit guarantee from the parent companies, the servicer is majority owned by SAIC Motor Corporation Limited (SAIC) and is strategically important to the auto business of its parents, SAIC and General Motors Company (GM, Baa3, stable).(2) Limited liquidity buffer: No liquidity reserve will be funded at closing and the only sources of liquidity are principal to pay interest mechanism and excess spread. Moody’s considered the following mitigants in determining the operational and liquidity risks in this transaction, which refer to operational disruptions, including non-timely payments on the notes due to non-performance by the transaction parties: (a) the strong parental support available to the servicer; (b) the credit quality of the servicer’s parents, SAIC and GM; (c) the short tenor of this transaction; and (d) the trustee will notify borrowers within 5 days of a servicer termination event. In the event that the servicer’s rating by domestic credit agencies falls below certain levels, the excess spread will be used to fund various reserve accounts. Moody’s has not relied, in its rating analysis, on triggers based on ratings assigned by other rating agencies.(3) Commingling risk with the servicer’s fund: The servicer will auto-debit the borrowers’ bank accounts on each of the loans’ monthly installment dates, and commingle such collections with its own funds. This amount will be subject to commingling risk until the servicer transfers such collections to the issuer’s account (7th business day of each month) prior to the immediate notes’ payment date (26th calendar day of each month). As a mitigant to commingling risk, the servicer will (a) immediately upon a rating downgrade (by domestic rating agencies), reduce the commingling period by transferring collections from the servicer account to the trust account within four business days upon receipt of funds by the servicer; (b) maintain various reserve funds using excess spread trapping upon a rating downgrade (by domestic rating agencies); and (c) put in place a servicing transfer plan within 90 days of a domestic ratings downgrade. Moody’s has considered the credit quality of the servicer and the payment mechanism in this transaction and incorporated one and a half months of cash commingling exposure in its modeling. Moody’s has not relied — in its rating analysis — on triggers based on ratings assigned by other rating agencies.(4) Lack of historical performance data during economically stressed period: The historical data provided covers the period from January 2014 to September 2021, a period that coincides with strong economic growth in China, except for the first and second quarter of 2020 where China economy was modestly affected by Covid-19. Accordingly, Moody’s has increased the mean default rate over those calculated with the historical pool performance data in the base-case analysis.MAIN MODEL ASSUMPTIONSMoody’s assumed a mean default rate of 1.2{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} and a portfolio credit enhancement of 7.5{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} for the securitized pool. A recovery rate of 15{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} is used as the other main input for Moody’s cash flow model ABSROM. These assumptions are made according to Moody’s analysis of the characteristics of such pools, their historical performance, and the current view of China’s social and macroeconomic conditions and risks as reflected in its local currency country ceiling of Aaa.RATING METHODOLOGYThe principal methodology used in these ratings was “Moody’s Global Approach to Rating Auto Loan- and Lease-Backed ABS” published in September 2021 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_1264141. Alternatively, please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.Factors that would lead to an upgrade or downgrade of the ratings:Factors that may cause a downgrade of the ratings include: (1) an increase in non-diversifiable country risk in China; (2) an increase in financial disruption risk, (3) a decline in the overall performance of the pool; (4) a significant deterioration in the credit profile of the originator or its parent companies and the absence of the implementation of any mitigating actions for the transaction, and (5) a deterioration in the credit quality of the transaction counterparties.The performance expectations for a given variable indicate Moody’s forward-looking view of the likely range of performance over the medium term. Performance that falls outside the given range may indicate that the collateral’s credit quality is stronger or weaker than what Moody’s had previously anticipated.THE COMPANYSAIC-GMAC is 55{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} owned by SAIC Motor Corporation Limited (SAIC) and 45{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996} owned by General Motors Company (GM, Baa3, stable). It is the first auto finance company established in China. It was established in August 2004 and is licensed under the supervision of the China Banking and Insurance Regulatory Commission (CBIRC). SAIC-GMAC has both a retail and wholesale business. The retail business provides auto loans to car purchasers of a number of brands, including GM and non-GM brands. The loans are originated through its dealership network across China.The issuer is a newly established special purpose trust incorporated in the China.REGULATORY DISCLOSURESFor further specification of Moody’s key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody’s Rating Symbols and Definitions can be found at: https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_79004.Moody’s took into account one or more third party due diligence assessment (s) regarding the underlying assets or financial instruments (the “Due Diligence Assessment(s)”) in this credit rating action and used the Due Diligence Assessment(s) in preparing the ratings. This had a neutral impact on the ratings.The Due Diligence Assessment(s) referenced herein were prepared and produced solely by parties other than Moody’s. While Moody’s uses Due Diligence Assessment(s) only to the extent that Moody’s believes them to be reliable for purposes of the intended use, Moody’s does not independently audit or verify the information or procedures used by third-party due-diligence providers in the preparation of the Due Diligence Assessment(s) and makes no representation or warranty, express or implied, as to the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of the Due Diligence Assessment(s).The analysis relies on an assessment of collateral characteristics to determine the collateral loss distribution, that is, the function that correlates to an assumption about the likelihood of occurrence to each level of possible losses in the collateral. As a second step, Moody’s evaluates each possible collateral loss scenario using a model that replicates the relevant structural features to derive payments and therefore the ultimate potential losses for each rated instrument. The loss a rated instrument incurs in each collateral loss scenario, weighted by assumptions about the likelihood of events in that scenario occurring, results in the expected loss of the rated instrument.Moody’s quantitative analysis entails an evaluation of scenarios that stress factors contributing to sensitivity of ratings and take into account the likelihood of severe collateral losses or impaired cash flows. Moody’s weights the impact on the rated instruments based on its assumptions of the likelihood of the events in such scenarios occurring.For ratings issued on a program, series, category/class of debt or security this announcement provides certain regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series, category/class of debt, security 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 credit rating action on the support provider and in relation to each particular credit 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.For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit 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.The ratings have been disclosed to the rated entity or its designated agent(s) and issued with no amendment resulting from that disclosure.These ratings are solicited. Please refer to Moody’s Policy for Designating and Assigning Unsolicited Credit Ratings available on its website www.moodys.com.Moody’s considers a rated entity or its agent(s) to be participating when it maintains an overall relationship with Moody’s. Unless noted in the Regulatory Disclosures as a Non-Participating Entity, the rated entity is participating and the rated entity or its agent(s) generally provides Moody’s with information for the purposes of its ratings process. Please refer to www.moodys.com for the Regulatory Disclosures for each credit rating action under the ratings tab on the issuer/entity page and for details of Moody’s Policy for Designating Non-Participating Rated Entities.Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.Moody’s general principles for assessing environmental, social and governance (ESG) risks in our credit analysis can be found at http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1288235.The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody’s affiliates outside the EU and is endorsed by Moody’s Deutschland GmbH, An der Welle 5, Frankfurt am Main 60322, Germany, in accordance with Art.4 paragraph 3 of the Regulation (EC) No 1060/2009 on Credit Rating Agencies. Further information on the EU endorsement status and on the Moody’s office that issued the credit rating is available on www.moodys.com.The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody’s affiliates outside the UK and is endorsed by Moody’s Investors Service Limited, One Canada Square, Canary Wharf, London E14 5FA under the law applicable to credit rating agencies in the UK. Further information on the UK endorsement status and on the Moody’s office that issued the credit rating is available on www.moodys.com.For PRC only: Neither MCO nor any of its majority-owned affiliates is a qualified credit rating agency within the PRC. Any rating assigned by MCO or any of its majority-owned affiliates: (1) does not constitute a rating as required under any relevant PRC laws or regulations; (2) cannot be included in any registration statement, offering circular, prospectus or any other documents submitted to the PRC regulatory authorities; and (3) cannot be used within the PRC for any regulatory purpose or for any other purpose which is not permitted under relevant PRC laws or regulations. For the purposes of this paragraph only, “PRC” refers to the mainland of the People’s Republic of China, excluding (i)Hong Kong SAR, China, (ii) Macau SAR, China and (iii) Taiwan, China.Please see www.moodys.com 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 for additional regulatory disclosures for each credit rating.The first name below is the lead rating analyst for this Credit Rating and the last name below is the person primarily responsible for approving this Credit Rating. Cecilia Chen Analyst Structured Finance Group Moody’s Investors Service Hong Kong Ltd. 24/F One Pacific Place 88 Queensway Hong Kong China (Hong Kong S.A.R.) JOURNALISTS: 852 3758 1350 Client Service: 852 3551 3077 Jerome Cheng Associate Managing Director Structured Finance Group JOURNALISTS: 852 3758 1350 Client Service: 852 3551 3077 Releasing Office: Moody’s Investors Service Hong Kong Ltd. 24/F One Pacific Place 88 Queensway Hong Kong China (Hong Kong S.A.R.) JOURNALISTS: 852 3758 1350 Client Service: 852 3551 3077 © 2021 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 CREDIT RATINGS AFFILIATES ARE THEIR CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND INFORMATION PUBLISHED BY MOODY’S (COLLECTIVELY, “PUBLICATIONS”) MAY INCLUDE SUCH CURRENT OPINIONS. MOODY’S 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 APPLICABLE MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S CREDIT RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS, NON-CREDIT ASSESSMENTS (“ASSESSMENTS”), AND OTHER OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY’S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY’S ANALYTICS, INC. AND/OR ITS AFFILIATES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS, ASSESSMENTS AND OTHER OPINIONS AND PUBLISHES ITS PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE.MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY’S PRIOR WRITTEN CONSENT.MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.All information contained herein is obtained by MOODY’S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS” without warranty of any kind. MOODY’S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY’S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY’S is not an auditor and cannot in every instance independently verify or validate information received in the rating process or in preparing its Publications.To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY’S.To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING, ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY’S IN ANY FORM OR MANNER WHATSOEVER.Moody’s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody’s Corporation (“MCO”), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody’s Investors Service, Inc. have, prior to assignment of any credit rating, agreed to pay to Moody’s Investors Service, Inc. for credit ratings opinions and services rendered by it fees ranging from $1,000 to approximately $5,000,000. MCO and Moody’s Investors Service also maintain policies and procedures to address the independence of Moody’s Investors Service credit ratings and credit rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold credit ratings from Moody’s Investors Service and have also publicly reported to the SEC an ownership interest in MCO of more than 5{21df340e03e388cc75c411746d1a214f72c176b221768b7ada42b4d751988996}, is posted annually at www.moodys.com under the heading “Investor Relations — Corporate Governance — Director and Shareholder Affiliation Policy.”Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided only to “wholesale clients” within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors.Additional terms for Japan only: Moody’s Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiary of Moody’s Group Japan G.K., which is wholly-owned by Moody’s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization (“NRSRO”). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any credit rating, agreed to pay to MJKK or MSFJ (as applicable) for credit ratings opinions and services rendered by it fees ranging from JPY125,000 to approximately JPY550,000,000.MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.
.jpg){kind=small}
