Research update (21 September 2012)
Transcription
Research update (21 September 2012)
Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Primary Credit Analyst: Alexandre Birry, London (44) 20-7176-7108; [email protected] Secondary Contact: Dhruv Roy, London (44) 20-7176-6709; [email protected] Table Of Contents Major Rating Factors Outlook Rationale Related Criteria And Research WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 1 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) SACP aa- Anchor a- Business Position Capital and Earnings Risk Position Funding + +1 + Additional Factors 0 Issuer Credit Rating Very Strong +2 Adequate 0 Strong +1 GRE Support 0 Group Support 0 AA/Negative/A-1+ Average 0 Liquidity Support Adequate Sovereign Support +1 Major Rating Factors Strengths: Weaknesses: • Market-leading franchise in The Netherlands. • Steady, long-term capital generation through earnings. • Relatively cautious management culture and strategy. • Strengthened funding and liquidity profiles. • Relatively elevated impairments on certain loan books, particularly in Ireland. • Some deterioration in domestic performance. • Mutual status somewhat constrains ability to raise capital, if required. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 2 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Outlook: Negative Standard & Poor's Ratings Services' outlook on Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) is negative, in line with that on the State of The Netherlands (unsolicited ratings AAA/Negative/A-1+). Under our criteria, with all other factors remaining the same, we would remove the one notch of government support currently factored into the long-term counterparty credit rating on Rabobank Nederland if we lowered the long-term unsolicited rating on The Netherlands by one notch (for further details, see table 22 in "Banks: Rating Methodology And Assumptions," published on Nov. 9, 2011). In addition to a sovereign downgrade, we could also lower the ratings if we see signs of a protracted further deterioration in the bank's asset quality, leading us to reassess its risk position. We could also take a similar action if a marked systemwide stress causes us to revise our view of the economic risk in the Netherlands under our Banking Industry Country Risk Assessment methodology. We would likely revise the outlook on Rabobank Nederland to stable if we revised the outlook on The Netherlands to stable, provided that asset quality trends stabilize. Rationale The starting point for our ratings on Rabobank Nederland is its 'a-' anchor, which is primarily based on our view of the banking system in its home market of The Netherlands. We consider its business position to be "very strong" (as defined by our criteria) due to its strong franchise in The Netherlands and its relatively prudent management approach. We view capital and earnings as "adequate" since we expect our risk-adjusted capital (RAC) ratio before diversification adjustments to remain within the 8.0%-8.5% range over the next 18 months. Our assessment of risk position is "strong" due to the relatively defensive profile of its balance sheet, underpinned by its large domestic residential mortgage portfolio. We view funding as "average" and liquidity as "adequate" since we consider that the relatively high loan-to-deposit ratio by international standards is mitigated by Rabobank Nederland's well-managed wholesale funding activity and increased liquid asset buffers. The ratings also reflect Rabobank Nederland's "high" systemic importance in The Netherlands, which takes into account its material market share in retail deposits in particular. Anchor The 'a-' anchor draws on our Banking Industry Country Risk Assessment (BICRA) methodology and our view of the weighted-average economic risk in the countries in which Rabobank Nederland operates, based on the geographic distribution of its private sector customer lending--The Netherlands (75%), the rest of Europe (10%), U.S. (10%), and the rest of the world (5%). The economic risk score for The Netherlands is '2' on a scale of 1-10 (1 is the lowest risk and 10 is the highest), and the weighted-average score for the countries in which Rabobank Nederland operates is close to that level. Our industry risk score for Rabobank Nederland is based solely on its home market of The Netherlands. The Dutch banking industry is dominated by three large players, of which Rabobank Nederland is one. The other two are subject to restructurings as a result of state aid that they had received. The sector's relatively large reliance on wholesale funding is partly attributable to households' propensity to save in life insurance and pension products. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 3 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Table 1 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Key Figures --Year-ended Dec. 31-(Mil. €) 2012* 2011 2010 2009 2008 Adjusted assets 767,904 728,863 648,861 603,962 608,392 Customer loans (gross) 492,380 471,174 458,551 438,439 429,582 31,767 31,641 21,440 19,697 18,573 Operating revenues 7,186 13,378 12,716 11,867 11,652 Noninterest expenses 4,551 8,720 8,196 7,304 7,611 905 1,942 2,239 1,902 2,560 Adjusted common equity Core earnings *Data as of June 30. Business Position: Exceptionally Stable And Resilient Franchise We consider Rabobank Nederland's business position to be "very strong," reflecting its exceptional stability and resilience, prudent management and strategy, and leading competitive position in its domestic market. Rabobank Nederland is a cooperative organization and it prioritizes steady, long-term franchise growth over short-term returns. In our view, this approach has enabled Rabobank Nederland to navigate the global financial crisis relatively comfortably. Stable revenue generation from the bank's domestic retail and commercial banking activities is a key supporting factor (see chart 1). This stability is underpinned by Rabobank Nederland's diversified product offering and its leading positions in Dutch household savings (39% market share at June 30, 2012), residential mortgages (28%), and lending to the trade, industry, and service sectors (43%). The bank's roots are in financing the Dutch agricultural sector, and it still dominates this market; its market share exceeds 80%. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 4 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Chart 1 Rabobank Nederland is less diversified internationally than several larger banks, but it is active outside The Netherlands in supporting Dutch clients and in its traditional core market of food and agriculture financing. Its international network is consequently focused on major agricultural centers in Europe, the Americas, and Australasia. It also conducts wholesale, commercial, and retail banking in selected countries. Wholesale banking activities are carried out under the trading name Rabobank International, which is a division of Rabobank Nederlands, rather than a separate legal entity. We consider that recent transactions--such as the absorption of a smaller Dutch bank, Friesland Bank, and the sale of its stake in Switzerland's Bank Sarasin--have had a broadly neutral impact on our view of the strength of Rabobank Nederland's franchise. Table 2 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Business Position --Year-ended Dec. 31-(%) 2012* 2011 2010 2009 2008 Total revenues from business line (currency in millions) 7,186.0 13,378.0 12,716.0 11,867.0 11,652.0 Retail banking/total revenues from business line 47.7 51.9 51.2 51.6 54.9 Commercial & retail banking/total revenues from business line 29.7 28.0 28.1 29.9 17.1 WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 5 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Table 2 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Business Position (cont.) Asset management/total revenues from business line 8.6 8.6 9.5 8.3 13.9 Other revenues/total revenues from business line 13.9 11.5 11.2 10.2 14.0 5.1 3.0 5.6 5.2 9.5 Return on equity *Data as of June 30. Capital And Earnings: Steady Capital Strengthening We view Rabobank Nederland's capital and earnings as "adequate." The risk-adjusted capital (RAC) ratio (based on our updated hybrid and BICRA criteria) before diversification adjustments is already consistent with an "adequate" assessment, and we expect it to remain in the 8.0%-8.5% range over the next 18 months. Rabobank Nederland's mutuality restricts to some extent its ability to raise new core capital, if required. However, it has issued deeply subordinated member certificates--classified as Core Tier 1 capital--to its customers and has demonstrated good access to the hybrid market. Its earnings capacity is somewhat constrained in our view because it does not seek to maximize profitability, as illustrated by its relatively low return on equity target of 8%. However, retained earnings, which benefit from the absence of common shareholder dividends, have consistently been sufficient to both support balance sheet growth and increase its core capital ratios, and we expect this model to continue. The RAC ratio before diversification adjustments was up by about one percentage point during the year to 8.2% at year-end 2011, the date of the last published Pillar 3 report (see table 3). During 2011, Rabobank Nederland re-issued the member certificates with stronger equity-like characteristics, and issued $4 billion in "new generation" Tier 1 instruments including write-down features. We classify the new Tier 1 issues as "intermediate" equity content hybrids under our criteria and included the member certificates in our adjusted common equity measure at year-end 2011 (see "S&P Includes Rabobank Nederland's New Member Certificates In ACE; Tier 1 Issue Classified As 'Intermediate' Hybrid," published on Dec. 13, 2011). We expect that the cost initiatives recently implemented, along with close management of the balance sheet, will enable the ratio to increase gradually further over the rating horizon, despite the difficult economic backdrop. Table 3 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Capital And Earnings --Year-ended Dec. 31-(%) 2012* 2011 2010 2009 Tier 1 capital ratio 16.9 17.0 15.7 13.8 12.7 S&P RAC ratio before diversification N.M. 8.2 7.1 7.6 N.M. S&P RAC ratio after diversification N.M. 10.0 8.6 9.2 N.M. Adjusted common equity/total adjusted capital 91.7 91.7 76.5 75.7 66.7 Net interest income/operating revenues 61.9 69.0 67.7 67.8 73.1 Fee income/operating revenues 20.8 22.3 22.3 21.7 24.8 Market-sensitive income/operating revenues N/A 3.5 2.6 (0.7) (10.4) Noninterest expenses/operating revenues 63.3 65.2 64.5 61.5 65.3 0.7 0.7 0.7 0.7 0.7 Preprovision operating income/average assets WWW.STANDARDANDPOORS.COM/RATINGSDIRECT 2008 SEPTEMBER 21, 2012 6 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Table 3 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Capital And Earnings (cont.) Core earnings/average managed assets 0.2 0.3 0.4 0.3 0.4 *Data as of June 30. N/A--Not applicable. N.M.--Not meaningful. Table 4 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) RACF [Risk-Adjusted Capital Framework] Data (Mil. €) Exposure* Basel II RWA Average Basel II RW (%) Standard & Poor's RWA Average Standard & Poor's RW (%) 110,829 1,788 2 3,325 3 Credit risk Government and central banks Institutions 29,145 7,288 25 6,870 24 Corporate 244,583 90,263 37 196,639 80 Retail 256,471 41,400 16 80,309 31 190,095 1,375 1 32,709 17 Securitization§ Of which mortgage 26,213 9,100 35 30,990 118 Other assets 17,298 37,013 214 18,332 106 684,539 186,850 27 336,466 49 4,267 13,225 763 45,925 1,076 -- 5,763 -- 8,144 -- -- 18,988 -- 54,068 -- -- -- -- 0 -- -- 17,775 -- 28,379 -- Basel II RWA Standard & Poor's RWA % of Standard & Poor's RWA 223,613 418,913 100 -- (74,886) (18) 223,613 344,027 82 Total credit risk Market risk Equity in the banking book† Trading book market risk Total market risk Insurance risk Total insurance risk Operational risk Total operational risk (Mil. €) Diversification adjustments RWA before diversification Total adjustments to RWA RWA after diversification Tier 1 capital Tier 1 ratio (%) Total adjusted capital Standard & Poor's RAC ratio (%) Capital ratio before adjustments 37,964 17.0 34,500 8.2 Capital ratio after adjustments† 37,964 17.0 34,500 10.0 (Mil. €) Capital ratio *Exposure at default. §Securitization exposure includes the securitization tranches deducted from capital in the regulatory framework. †Exposure and Standard & Poor's risk-weighted assets for equity in the banking book include minority equity holdings in financial institutions. ‡Adjustments to Tier 1 ratio are additional regulatory requirements (e.g., transitional floor or Pillar 2 add-ons). RWA--Risk-weighted assets. RW--Risk weight. RAC--Risk-adjusted capital. Sources: Company data as of Dec. 31, 2011, Standard & Poor's. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 7 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Risk Position: Underpinned By Domestic Mortgage Book Rabobank Nederland's risk position is "strong," in our opinion. In particular, we consider that the standard capital charges applied to its assets in the RAC framework are generally conservative in view of the better-than-average risk profile of its balance sheet. Its long-term average bad debt cost of 25 basis points (bps) illustrates its focus on lower-risk, more-stable sectors, although the cost has increased recently because of the weaker economy. Asset quality is largely underpinned by the large domestic residential mortgage book, which represented 45% of Rabobank Nederland's private sector lending at June 30, 2012 (see chart 2). The asset quality track record of this portfolio has been among the best in the Netherlands. It has a very low and stable long-term average bad debt cost of about 5 bps. Although its domestic market accounts for close to three-quarters of total lending, Rabobank is active across all parts of the Dutch economy, without undue concentrations. This is reflected in a diversification benefit of 18% at end-2011 under our RAC methodology. International operations have recently refocused on the food and agriculture sectors in which Rabobank has longstanding expertise and competitive advantages. Chart 2 Rabobank Nederland has not been immune from the difficult economic and market conditions, however, and it has incurred elevated impairments and write-downs in certain international markets in recent times, particularly in Ireland and earlier in U.S. structured credit. These losses were recognized at a relatively early stage, and the group was able to manage them due to the small size of the underlying portfolios in the context of the consolidated balance sheet. We observe that asset quality in certain domestic portfolios, such as commercial real estate and certain SME sectors, WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 8 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) has deteriorated since the second half of 2011; this is in line with other Dutch players. We consider that Rabobank Nederland can manage the deterioration to date, supported by the adequate diversification of its overall exposures. We consider the provisioning levels of the related impaired exposures to be sound. Also, we observe that loan losses remain smaller than normalized losses derived from our RAC framework. Our base-case view is that Rabobank Nederland's impairments should remain elevated relative to historical average for the rest of 2012, and that it will gradually improve from 2013. We expect the reduction in the charge in Ireland to be more than offset by the increased provisioning levels in The Netherlands, on the back of a weak economic outlook in the near term. Table 5 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Risk Position --Year-ended Dec. 31-(%) 2012* 2011 2010 2009 2008 9.0 2.8 4.6 2.1 14.5 Total diversification adjustment/S&P RWA before diversification N.M. (18.0) (17.6) (17.6) N.M. Total managed assets/adjusted common equity (x) 25.8 23.1 30.4 30.9 33.0 Growth in customer loans New loan loss provisions/average customer loans Net charge-offs/average customer loans 0.5 0.3 0.3 0.5 0.3 N.M. 0.3 0.3 0.2 0.1 2.3 2.1 2.0 2.1 1.5 34.2 31.0 28.1 49.2 50.2 Gross nonperforming assets/customer loans + other real estate owned Loan loss reserves/gross nonperforming assets *Data as of June 30. RWA--Risk-weighted assets. N.M.--Not meaningful. Funding And Liquidity: Strong Deposit Franchise And Well-Managed Wholesale Funding Base Rabobank Nederland's funding is "average" and liquidity position is "adequate", in our opinion. As is the norm in the Dutch market, its loan-to-deposit ratio is relatively high, at 143% at June 30, 2012, despite its leadership position in the domestic deposit market. Strong inflows of deposits, despite continued lending growth, have led to some improvement in the ratio since end-2010, when the ratio stood at 154%. The bank has maintained good access to both public and private wholesale funding markets through the crisis and has taken advantage of opportunities to extend the maturity profile of debt issues. The average maturity of debt issued in recent years exceeds five years and the bank has issued several 10-year bonds in the year-to-date, despite volatile market conditions. Rabobank Nederland's liquidity position has strengthened materially over the past few years. The bank maintains a surplus of liquid assets well in excess of regulatory requirements. At end-June 2012, it reported a liquidity buffer of €159 billion--broadly stable since end-2011--€67 billion of which was in cash, mainly placed at the ECB. A further €48 billion was in the form of government debt and the remainder consisted of other assets eligible for repo activity with central banks. We estimate that this buffer significantly exceeds the volume of wholesale maturities over 12 months. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 9 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Table 6 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Funding And Liquidity --Year-ended Dec. 31-(%) 2012* 2011 2010 2009 2008 53.9 54.2 53.2 55.2 62.0 Customer loans (net)/customer deposits 143.3 143.1 153.6 152.2 140.4 Long term funding ratio N.M. 71.1 69.8 N.M. N.M. Broad liquid assets/short-term wholesale funding (x) N.M. 1.1 0.8 N.M. N.M. Net broad liquid assets/short-term customer deposits N.M. 2.7 (9.2) N.M. N.M. Net short-term interbank funding/total wholesale funding N.M. (0.1) (3.4) N.M. N.M. Short-term wholesale funding/total wholesale funding N.M. 47.4 46.4 N.M. N.M. Core deposits/funding base *Data as of June 30. N.M.--Not meaningful. External Support: High Systemic Importance In The Netherlands The long-term counterparty credit rating on Rabobank Nederland is one notch higher than the stand-alone credit profile (SACP), reflecting our view that it has high systemic importance in The Netherlands and that the government is supportive toward its banking sector. Our assessment of Rabobank Nederland's systemic importance partly reflects its material market shares in retail deposits and residential mortgages. Related Criteria And Research • • • • • No Pain, No Gain: How The Housing Market Correction Is Affecting Dutch Banks, Jun. 27, 2012 Banks: Rating Methodology And Assumptions, Nov. 9, 2011 Group Rating Methodology And Assumptions, Nov. 9, 2011 Banking Industry Country Risk Assessment Methodology And Assumptions, Nov. 9, 2011 Bank Hybrid Capital Methodology And Assumptions, Nov. 1, 2011 Anchor Matrix Economic Risk Industry Risk 1 1 2 3 4 5 6 7 8 9 10 a a a- bbb+ bbb+ bbb - - - - 2 a a- a- bbb+ bbb bbb bbb- - - - 3 a- a- bbb+ bbb+ bbb bbb- bbb- bb+ - - 4 bbb+ bbb+ bbb+ bbb bbb bbb- bb+ bb bb - 5 bbb+ bbb bbb bbb bbb- bbb- bb+ bb bb- b+ 6 bbb bbb bbb- bbb- bbb- bb+ bb bb bb- b+ 7 - bbb- bbb- bb+ bb+ bb bb bb- b+ b+ 8 - - bb+ bb bb bb bb- bb- b+ b 9 - - - bb bb- bb- b+ b+ b+ b 10 - - - - b+ b+ b+ b b b- WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 10 1014949 | 301308293 Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Ratings Detail (As Of September 21, 2012) Cooperatieve Centrale Raiffeisen-Boerenleenbank B.A. (Rabobank Nederland) Counterparty Credit Rating AA/Negative/A-1+ Junior Subordinated A Preferred Stock A Senior Unsecured Greater China Regional Scale cnAAA Senior Unsecured A-1+ Senior Unsecured AA Senior Unsecured AA/A-1+ Short-Term Debt A-1+ Subordinated A+ Counterparty Credit Ratings History 23-Jan-2012 AA/Negative/A-1+ 07-Dec-2011 AA/Watch Neg/A-1+ 29-Nov-2011 AA/Stable/A-1+ 08-Dec-2009 AAA/Negative/A-1+ Sovereign Rating Netherlands (The) (State of) (Unsolicited Ratings) AAA/Negative/A-1+ Related Entities Cooperative Centrale-Raiffeisen Boerenleenbank B.A. (New York Branch) Senior Unsecured AA Short-Term Debt A-1+ Rabobank New Zealand Ltd. Issuer Credit Rating AA/Negative/A-1+ Rabobank USA Financial Corp. Issuer Credit Rating --/--/A-1+ Rabo Capital Securities Ltd. Junior Subordinated A Rabohypotheekbank N.V. Issuer Credit Rating AA/Negative/-- *Unless otherwise noted, all ratings in this report are global scale ratings. Standard & Poor's credit ratings on the global scale are comparable across countries. Standard & Poor's credit ratings on a national scale are relative to obligors or obligations within that specific country. Additional Contact: Financial Institutions Ratings Europe; [email protected] WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 11 1014949 | 301308293 Copyright © 2012 by Standard & Poor's Financial Services LLC. All rights reserved. No content (including ratings, credit-related analyses and data, model, software or other application or output therefrom) or any part thereof (Content) may be modified, reverse engineered, reproduced or distributed in any form by any means, or stored in a database or retrieval system, without the prior written permission of Standard & Poor's Financial Services LLC or its affiliates (collectively, S&P). The Content shall not be used for any unlawful or unauthorized purposes. S&P and any third-party providers, as well as their directors, officers, shareholders, employees or agents (collectively S&P Parties) do not guarantee the accuracy, completeness, timeliness or availability of the Content. S&P Parties are not responsible for any errors or omissions (negligent or otherwise), regardless of the cause, for the results obtained from the use of the Content, or for the security or maintenance of any data input by the user. The Content is provided on an "as is" basis. S&P PARTIES DISCLAIM ANY AND ALL EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, FREEDOM FROM BUGS, SOFTWARE ERRORS OR DEFECTS, THAT THE CONTENT'S FUNCTIONING WILL BE UNINTERRUPTED, OR THAT THE CONTENT WILL OPERATE WITH ANY SOFTWARE OR HARDWARE CONFIGURATION. In no event shall S&P Parties be liable to any party for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profits and opportunity costs or losses caused by negligence) in connection with any use of the Content even if advised of the possibility of such damages. Credit-related and other analyses, including ratings, and statements in the Content are statements of opinion as of the date they are expressed and not statements of fact. S&P's opinions, analyses, and rating acknowledgment decisions (described below) are not recommendations to purchase, hold, or sell any securities or to make any investment decisions, and do not address the suitability of any security. S&P assumes no obligation to update the Content following publication in any form or format. The Content should not be relied on and is not a substitute for the skill, judgment and experience of the user, its management, employees, advisors and/or clients when making investment and other business decisions. S&P does not act as a fiduciary or an investment advisor except where registered as such. While S&P has obtained information from sources it believes to be reliable, S&P does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives. To the extent that regulatory authorities allow a rating agency to acknowledge in one jurisdiction a rating issued in another jurisdiction for certain regulatory purposes, S&P reserves the right to assign, withdraw, or suspend such acknowledgement at any time and in its sole discretion. S&P Parties disclaim any duty whatsoever arising out of the assignment, withdrawal, or suspension of an acknowledgment as well as any liability for any damage alleged to have been suffered on account thereof. S&P keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of their respective activities. As a result, certain business units of S&P may have information that is not available to other S&P business units. S&P has established policies and procedures to maintain the confidentiality of certain nonpublic information received in connection with each analytical process. S&P may receive compensation for its ratings and certain analyses, normally from issuers or underwriters of securities or from obligors. S&P reserves the right to disseminate its opinions and analyses. S&P's public ratings and analyses are made available on its Web sites, www.standardandpoors.com (free of charge), and www.ratingsdirect.com and www.globalcreditportal.com (subscription), and may be distributed through other means, including via S&P publications and third-party redistributors. Additional information about our ratings fees is available at www.standardandpoors.com/usratingsfees. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT SEPTEMBER 21, 2012 12 1014949 | 301308293