Principal Stability Fund Ratings

Standard & Poor’s Fund Ratings
How S&P applies its Fund Ratings Criteria to
Local Government Investment Pools
Government Investment Officers Association Annual Conference
Anthony Ivancich
Client Business Manager, Associate Director
Fund Ratings & U.S. Public Finance Ratings
March 21, 2012
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
Copyright © 2011 Standard & Poor’s Financial Services LLC, a subsidiary of The McGraw-Hill Companies, Inc. All rights reserved.
Agenda/Talking Points
•
Overview of the Fund Ratings Group
•
Principal Stability Fund Ratings (PSFRs) or ‘m’ ratings
•
Fund Credit Quality & Volatility Ratings (FCQRs & FVRs) or ‘f’ ratings
•
Differences between ‘m’ & ‘f’ ratings
•
Reasons Why Pools Request Ratings
•
Fund Rating Process and Additional Services
•
Surveillance Process
•
Rated Government Investment Pools (LGIPs) Indices
•
Impact of Recent US Downgrade on Rated LGIPs
•
Q&A
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
2.
Overview of Standard & Poor’s Fund Ratings
•
Rating Funds Since December 1983
•
Funds Group Officially Formed In 1989
•
Provide value-added fund safety, credit and volatility ratings, portfolio
evaluations, monitoring for fixed-income funds, government investment pools,
exchange traded funds, separate accounts and municipal debt issuers
•
Comprised of 20+ fund analysts in 5 countries averaging 10+ years of fixedincome and fund ratings experience
•
Provides ratings and evaluations for over 950+ “funds” globally, from over 250
sponsors:
 750+ Principal Stability Fund Ratings
 200+ Fund Credit and Volatility Rated funds
 Includes 90+ Local Government Investment Pools
 Includes approximately 60+ Liquidity Assessments
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
3.
States with Rated Local Government Investment Pools/Portfolios
States With Standard & Poor's Rated Local Government Investment Pools/Portfolios
WA
MT
M
E
ND
OR
VT
MN
NH
ID
SD
NY
WI
WY
RI
NV
NJ
NE
UT
OH
IL
DE
IN
CO
NC
TN
AR
SC
MS
TX
VA
KY
OK
NM
MD
WV
MO
KS
AZ
CT
PA
IA
CA
MA
MI
AL
GA
LA
AK
FL
LEGEND
Puerto Rico has a Rated LGIP which is Sub-Advised (YELLOW)
HI
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
4.
No Pool Ratings
Rated & Run by Gov't Entity
(State/County/City)
Rated & Run by Non-Gov't Entity
(Sub- Advisor/Private Firm)
Rated & Run by Gov't Entity & Non-Gov't Entity
(State/County/City/Private Firm/Sub-Advisor)
Number of Rated Pools
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
5.
Total S&P Rated LGIP Assets
Year
Month
2001
December
$69,064.90
2002
December
$81,204.73
2003
December
$81,147.79
2004
December
$99,023.64
2005
December
$117,860.12
2006
December
$139,186.27
2007
December
$185,784.32
2008
December
$208,510.00
2009
December
$180,611.00
2010
December
$201,493.00
2011
November
$182,008.00
(As of November 2011)
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
6.
Market Value
Totals (Mil.)
List of Principal Stability Rated LGIP’s
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
7.
List of Principal Stability Rated LGIP’s (continued)
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
8.
List of Fund Credit Quality Rated LGIP’s
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
9.
Types of Government Investment Pool (Fund) Ratings
Principal Stability Fund Ratings
• Assigned to funds whose investment
policies are consistent with providing a
stable or accumulating NAV (i.e. 2a-7 $1.00
NAV funds)
 max WAM to Reset 60 days (AAAm)
 max WAM to Final 90-120 days (AAAm)
 max final maturity 397 days (fixed rate)
 high credit quality (Tier 1 only)
 highly diversified (issuers, counterparties,
etc.)
Fund Credit Quality & Volatility Ratings
• Assigned to funds with investment policies
beyond what is permitted by rule 2a-7 (i.e.
Variable NAV Funds)
 max WAM to Reset > 90 days
 max WAM to Final > 120 days
 max final maturity > 397 days (fixed
rate)
• Fund Credit Quality Ratings
• Also known as Money Market Fund Ratings
or Stable NAV Fund Ratings
Addresses level of protection a fund’s
portfolio holdings provide against
losses from credit defaults
• Represented by ‘m’ suffix after the
traditional rating symbology (AAAm)
Represented by ‘f’ suffix after the
traditional rating symbology (AAAf)
• Address the ability of a fund to maintain
principal stability and to limit exposure to
principal losses due to credit risk
• Fund Volatility Ratings
Represented by ‘S’ scale (S1, S2, etc.)
Addresses a fund’s sensitivity to
changing market conditions
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
10.
Risk (Credit & Market)
Estimated Risk/Reward Tradeoff of S&P Fund Ratings
AAAf
S1+ & S1
AAf
S2
Am
AAm
AAAm
Reward
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
11.
Af
S3
BBBf
S4
Principal Stability Fund Ratings
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
12.
Rated Principal Stability Fund (MMF) Statistics (US)
# Rated Taxable Funds
# Rated Tax Exempt Funds
Total # Rated Funds
May-07
666
100
766
Jun-08
728
127
855
Jun-09
675
104
779
Jun-10
657
109
766
Jun-11
652
114
766
Rated Taxable-Assets (Billions)
Rated Tax-Exempt-Assets (Billions)
Overall Rated Funds-Assets (Billions)
May-07
$
1,016
$
90
$
1,106
Jun-08
$
1,737
$
150
$
1,887
Jun-09
$
2,091
$
139
$
2,230
Jun-10
$
1,525
$
106
$
1,631
Jun-11
$
1,549
$
97
$
1,646
Source: Rated Money Fund Report
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
13.
Principal Stability Fund Ratings Definitions
AAAm
A fund rated 'AAAm' demonstrates extremely strong capacity to maintain principal
stability and to limit exposure to principal losses due to credit risk. 'AAAm' is the highest
principal stability fund rating assigned by Standard & Poor's.
AAm
A fund rated 'AAm' demonstrates very strong capacity to maintain principal stability and to
limit exposure to principal losses due to credit risk. It differs from the highest-rated funds
only to a small degree.
Am
A fund rated 'Am' demonstrates strong capacity to maintain principal stability and to limit
exposure to principal losses due to credit risk, but is somewhat more susceptible to the
adverse effects of changes in circumstances and economic conditions than funds in
higher-rated categories
BBBm
A fund rated 'BBBm' demonstrates adequate capacity to maintain principal stability and to
limit exposure to principal losses due to credit risk. However, adverse economic conditions
or changing circumstances are more likely to lead to a reduced capacity to maintain
principal stability.
BBm
A fund rated 'BBm' demonstrates speculative characteristics and uncertain capacity to
maintain principal stability. It is vulnerable to principal losses due to credit risk. While such
funds will likely have some quality and protective characteristics, these may be outweighed
by large uncertainties or major exposures to adverse conditions.
Dm
A fund rated 'Dm' has failed to maintain principal stability resulting in a realized or
unrealized loss of principal.
Plus (+) or minus (-) The ratings may be modified by the addition of a plus (+) or minus (-) sign to
show relative standing within the rating categories.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
14.
Overview of Standard & Poor’s Fund Ratings
A S&P Principal Stability Fund Rating Is…
A S&P Principal Stability Fund Rating Is NOT…
• An opinion on relative safety of invested
principal.
• A guarantee.
• An indication of the extent to which a
portfolio is comprised of high credit quality
instruments.
• An indication of the willingness and/or ability of
sponsor to provide support.
• A comment on the yield or performance.
• An indication investments are risk free.
• A weekly review of the investment holdings
and key fund statistics including but not
limited to NAV, WAM and asset flows.
• An indication of the extent to which a fund
provides principal stability.
• Impacted by fund management’s decision to
make payments in kind versus cash.
• Impacted by a fund management’s decision to
suspend redemptions (i.e. do not guarantee daily
liquidity).
• An independent, third party review of
management’s experience, operations and
controls.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
15.
PSFR Criteria Summary Table (Changes in Red)
Rating
AAAm
Minimum Maximum Maximum Maximum
A-1+ &
A-1
WAM (R) in WAM (F) in
A-1 ≤ 5 > 5 business
Days
Days¶
business
days*
days
50%
50%
60
90
NAV
Ranges §
Max Final
Maturity
Per Fixed Rate
Security
Max Final
Maturity
Per Floating
Rate Security
0.25%
(0.9975 to 1.0025)
13 months
(397 days)
Two Years
(762 days)
AAm
20%
80%
70
100
0.30%
(0.9970 to 1.0030)
13 months
(397 days)
Three Years
(1,127 days)
Am
0%
100%
80
110
0.35%
(0.9965 to 1.0035)
13 months
(397 days)
Four Years
(1,492 days)
BBBm
0%
100%
90
120
0.40%
(0.9960 to 1.0040)
13 months
(397 days)
Five Years
(1,857 days)
*Exposures to securities rated below 'A-1' are "higher-risk investments."
¶ May be adjusted upward by 30 days if invested only in government/GSE floaters rated 'AA-' or higher. If a fund
invests in a combination of government floaters rated 'AA-' or higher and nongovernment floating-rate
instruments (or sovereigns rated below 'AA-'), the maximum is based on the weighted average of exposures to
each type of floater.
§For all funds, regardless of rating, daily portfolio pricing, daily marked-to-market NAV calculations, and daily
stress testing commence when NAV goes beyond +/- 0.15% deviation or 0.9985 or 1.0015.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
16.
Differences in Criteria for Rated & Unrated PSFRs
Non
Rated
AAAm
Rated
AAm
Rated
Am
Rated
Max Fund WAM (R)
60 days
60 days
70 days
80 days
Max Fund WAM (F)
120 days
90* days
100* days
110* days
Max maturity per security
(Floating - Government)
None
2 years
3 years
4 years
Max maturity per security
(Fixed & Floating - Corp)
397 days
397 days
397 days
397 days
Minimum A-1+ allocation
N/A
50%
20%
0%
Maximum A-1 allocation
N/A
50%
80%
100%
Maximum A-2 allocation
3%
0%
0%
0%
Discretionary
Weekly
Weekly
Weekly
Max per Security/Industry
5%/25%
5%/25%
5%/25%
5%/25%
Max per Repo Counterparty
Unrestricted
Restricted
Restricted
Restricted
10%/30%
N/A
N/A
N/A
Maturity
Credit Quality
Pricing
Frequency
Diversification
Minimum Liquidity
Overnight/7 days
* WAM(F) criteria for all rating categories may be adjusted upward by 30 days (e.g. 'AAAm' 120 days) if a fund invests only in national government (sovereign)
and/or government-sponsored entity (GSE) floating-rate notes. In addition, if a fund invests in a combination of government and nongovernment floating-rate
instruments, a sliding scale between 90 and 120 days will be applied based on percentage exposures to each type of floater.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
17.
Cure Periods
Metric/Threshold Category
Cure Period*
NAV
Up to 5 business days
% of portfolio
Downgrades below ‘A-1’
≤0.5%
>0.5% ≤ 1.0%
>1.0% ≤ 5.0%
>5%
= 397 calendar days
= 120* calendar days
= 60* calendar days
= 7 calendar days
* Regardless of the short-term rating, if the long-term rating is 'BBB+' and on CreditWatch
negative or 'BBB' or lower, the cure period drops to seven calendar days.
Maturity
10 business days
10% illiquid/limited liquidity bucket
10 business days
Diversification
10 business days
Overall Credit Quality
(i.e., 50% maximum in A-1)
10 business days
* NOTE: The cure period related to a breach applies only to that specific metric/threshold and to no others and
begins on the date the breach occurs. All cure periods are based on a fund's NAV remaining within the ranges
outlined for each rating category (i.e., AAAm +/- 0.25%)
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
18.
Fund Credit Quality & Volatility Ratings
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
19.
Fund Credit Quality Ratings Symbols & Definitions
AAAf
Portfolio holdings provide EXTREMELY STRONG protection against losses
from credit defaults
AAf
Portfolio holdings provide VERY STRONG protection against losses from
credit defaults
Af
Portfolio holdings provide STRONG protection against losses from credit
defaults
BBBf
Portfolio holdings provide ADEQUATE protection against losses from credit
defaults
BBf
Portfolio holdings provide UNCERTAIN protection against losses from credit
defaults
Bf
CCCf
Portfolio holdings provide VULNERABLE protection against losses from
credit defaults
Portfolio holdings provide EXTREMELY VULNERABLE protection against
losses from credit defaults
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
20.
Fund Credit Quality Ratings Methodology
 Evaluation of Fund’s Portfolio Credit Risk
 Use of credit matrix approach derived from S&P’s historical default and ratings transition
studies based on singular, discrete, worst-case one-year default rates experienced since
1981.
 Factors and scores from matrix applied to fund’s portfolio holdings.
 All securities rated by a nationally recognized statistical rating organisation.
 Maturity of Securities Considered
 Maturity buckets within matrix distinguish long term securities from short term securities.
 Recognises that probability of default decreases as security nears maturity.
 Treatment of Non-Standard & Poor’s Rated Issues
 Securities rated by other rating agencies (not exceeding 25% in total) are “haircut” for
purposes of credit matrix score.
 Management
 Detailed assessment of depth and quality of research and analysis, consistency of approach,
and risk tolerance.
 Qualitative Credit Overlay Process
 The strength of manager’s overall credit analysis may allow rating to be enhanced by one
notch.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
21.
S&P Fund Credit Quality Rating Matrix
RATING Factors
AAA
0
AA+
20
AA
20
AA20
A+
50
A
50
A50
BBB+
250
BBB
250
BBB250
BB+
1000
BB
1000
BB1000
B+
4000
B
4000
B4000
CCC+
20000
CCC
20000
CCC20000
A-1+
A-1
A/A-2
A-/A-2
BBB+/A-2
BBB/A-2
BBB/A-3
BBB-/A-3
TOTALS =
Enter Fund %s Here
> 90 but
< = 90 days
< = 365 days
> 365 days
0.00%
0.00%
0.00%
Contribution
to Score
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00%
Scores
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
22.
Rating Fixed Score
0-7
AAAf
8 - 10
AA+f
11 - 20
AAf
21 - 25
AA-f
26 - 35
A+f
36 - 50
Af
51 - 90
A-f
91 - 150
BBB+f
151 - 250
BBBf
251 - 450
BBB-f
451 - 775
BB+f
776 - 1000
BBf
1001 - 1850
BB-f
1851 - 2520
B+f
2521 - 4000
Bf
4001 - 7800
B-f
7801 - 14700 CCC+f
14700 +
CCCf
7
10
20
25
35
50
90
150
250
450
775
1000
1850
2520
4000
7800
14700
20000
Principal Stability Fund Ratings Definitions
Rating
Pool’s Sensitivity To
Changing Market Conditions
Aggregate Risk Level
S1*
S2
S3
S4
S5
S6
Low
Low To Moderate
Moderate
Moderate To High
High
Highest
1 To 3 Year U.S. Governments
3 To 7 Year U.S. Governments
7 To 10 Year U.S. Governments
10+ Year U.S. Governments
Concentrated, Illiquid /Leveraged
Highly Speculative
* Within the S-1 category certain pools may be designated with a plus sign (+). This indicates the
pool’s extremely low sensitivity to changing market conditions. Additionally, these pools possess a risk
level that is less than or equal to a portfolio comprised of the highest quality instruments with an
average maturity of one year or less.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
23.
Volatility Ratings Methodology
Portfolio-level risk analysis
 Focuses on interest rate risk, currency risk, credit quality, liquidity, concentration,
call and option risks. The effects of various portfolio strategies such as the use of
leverage, hedging, and derivative instruments are also factored in.
Historical return volatility analysis
 A minimum of 36 months are looked at in relation to established fixed income
government indices with different maturity bands and we review how past volatility
relates to the portfolio’s investment objectives and construction process
Management assessment
 In depth understanding of different factors that could affect a fund’s overall risk
profile: Management sophistication and experience, portfolio strategies, internal
research capabilities, risk controls, portfolio rotation, etc.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
24.
Process & Application of Criteria
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
25.
Summary of Main Differences Amongst ‘m’& ‘f’ ratings
Principal Stability Fund Ratings; aka Money Market Fund
Ratings (eg. ‘AAAm’)
Fund Credit Quality & Volatility Ratings; aka Bond
Fund Ratings
(eg. ‘AAAf/S1’)
Eligible Investments We require a short term rating of at least ‘A-1’. If it is not rated by The securities must be rated by S&P or another NRSRO.
(According to Rating) S&P but has the highest short-term rating of another NRSRO, it If it is unrated by S&P, certain notching rules may apply.
must either be backed by a highly rated LOC provider, or have an
S&P long term rating of at least ‘AA’.
Ratings Breakdown
For ‘AAAm’ rated funds, at least 50% must be in ‘A-1+’, with the
other 50% in ‘A-1’ securities. For ‘AAm’ funds, 20% is required in
‘A-1+’, with the other 80% in ‘A-1’ securities, with up to 5% in
overnight ‘A-2’ securities. For ‘Am’ funds, 100% may be in ‘A-1’,
with up to 10% in overnight ‘A-2’ securities.
Types of Securities
Common security types are Repurchase Agreements, Fixed and Common security types are Mortgage Backed Securities,
Floating Corporate Bonds, Commercial Paper, Certificates of
Fixed and Floating Rate Corporate Bonds, Commercial
Deposits, U.S. Treasury Securities, U.S. Agency Securities, etc. Paper, Certificates of Deposits, U.S. Treasuries, U.S.
Agencies, Municipal Bonds, etc.
Reporting Frequency Fund must submit weekly surveillance.
There is no minimum requirement, but the outcome of the
rating will be dependent on our “ratings matrix.” The Fund
Credit Quality Ratings Matrix takes into account the
rating on the security (long term or short term), the
maturity (< 90 days, > 90 but < = 365 days, > 365 days),
and the percentage held by the fund in each security.
Fund must submit monthly surveillance.
NAV
When the NAV of a ‘AAAm’ rated fund moves outside 0.9985 and The NAV may fluctuate but a material deviation may
1.0015, daily pricing is required. If the NAV for a ‘AAAm’ fund
impact the fund volatility rating.
continues to deviate beyond 0.9975 or 1.0025, rating action may
be taken.
Weighted Average
Maturity (WAM)
Guidelines
‘AAAm’ - 60 days, ‘AAm’ - 75 days, ‘Am’ and ‘BBBm’ - 90 days
There is no WAM limit, but the longer the maturity dates,
the more likely it is that the security will contribute to a
lower rating.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
26.
Why Do Managers Request an S&P Fund Rating?
 Asset Growth / Retention
 Third Party Credibility
 Board Oversight
 Diversified Product Mix
 Regulatory/Compliance
 N.A.I.C. Reduced Capital Reserve Requirements - Investments by insurance
companies in AAAm rated funds have 0% capital reserve requirements.
Capital reserve requirements are reduced to 1% when investing into AAm or
Am rated money market funds or AAAf rated government bond funds.
 State & Local Governments - GFOA recommends AAAm rated funds as
investments for local & state governments.
 Bond Proceeds - AAAm rated funds are Eligible Investments for bond
proceeds of Standard & Poor’s rated debt issues
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
27.
How are Funds/Pools Rated?
Source : Guide to Credit Rating Essentials
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
28.
Sample Components of S&P Fund Rating Analysis
Quantitative
• Overall portfolio credit quality
• Individual security credit quality
• Counterparty risk and exposure
• Diversification of securities
• Credit Deterioration vs. Default
• Net Asset Value Stability
• Weighted Average Maturity (WAM) /
Duration
Qualitative
• Depth and stability of organization &
management team
• Experience and track record of fund
manager
• Operating policies and risk preferences
• Internal controls
• Fund Governance
• Communication with S&P and commitment
to rating
• Maturity Structure (Ladder vs. Barbell)
• Pricing
• Liquidity
• Shareholder Composition/Asset
Volatility
• Structured & Variable / Floating Rate
Notes
• Leverage: Rev Repo/Sec Lending
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
29.
Surveillance (Monitoring) of Fund Ratings
•
Dedicated Staff of Surveillance Analysts & Proprietary Systems (WebDC &
MFDB)
•
Portfolio Holdings, Cash Flows & Risk Parameters are reviewed:
•
 Weekly for Stable NAV Pools
•
 Monthly for Variable NAV Pools
•
Portfolio Level & Security Level Analysis
»
»
»
»
»
»
»
»
portfolio maturity
credit quality
illiquid and market sensitive securities
sector allocations
variable / floating rate instruments
net asset value (pricing) fluctuations
comparison of CDS vs. current ratings
highest yielding fund analysis
•
Internal Monthly Surveillance Meetings to Review Material Events
•
Frequent Communication with Fund Management
•
Annual On-Site Management Review Meeting
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
30.
Sample of Surveillance Summary Information
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
31.
PSFR Sensitivity Matrix
WAM (R)
WAM (F)
Shares Outstanding:
Total Fund Assets:
Market Value (NAV):
Credit Spread Movement (bps):
% Total Credit (Non Gov't) Securities (of portfolio)
% Corporate Floaters (of portfolio)
60 Copyright© 2010 by Standard & Poor’s Financial Services LLC (S&P) a subsidiary of The McGraw-Hill Companies, Inc. All rights reserved.
120
501,000,000.00
500,248,500.00
0.998500
50
FILL IN/ADJUST AREAS SHADED GREEN TO RUN SCENARIOS
25%
15%
Total $ Loss:
($751,500)
Total $ Gain:
$0
Selected Shareholders
0.992310
0.993245
0.994180
0.994648
0.995115
0.995583
0.996050
0.996517
Largest Redemption
over 5 consecutive
business days
0.991220
0.992288
0.993355
0.993889
0.994423
0.994956
0.995490
0.996024
0.991550
0.992577
0.993604
0.994118
0.994632
0.995146
0.995659
0.996173
0.992489
0.993402
0.994315
0.994772
0.995228
0.995685
0.996142
0.996598
0.992884
0.993749
0.994614
0.995047
0.995479
0.995912
0.996345
0.996777
0.993240
0.994062
0.994884
0.995295
0.995705
0.996116
0.996527
0.996938
0.993562
0.994344
0.995127
0.995519
0.995910
0.996301
0.996693
0.997084
0.994366
0.995051
0.995736
0.996079
0.996421
0.996764
0.997106
0.997449
Gain (Loss)
(3,386,897)
(2,975,116)
(2,563,336)
(2,357,445)
(2,151,555)
(1,945,664)
(1,739,774)
(1,533,884)
50
25
0
-25
-50
-75
0.996985
0.997452
0.997920
0.998387
0.998855
0.999322
0.996558
0.997091
0.997625
0.998159
0.998692
0.999226
0.996687
0.997200
0.997714
0.998228
0.998741
0.999255
0.997055
0.997511
0.997968
0.998425
0.998881
0.999338
0.997210
0.997642
0.998075
0.998508
0.998940
0.999373
0.997349
0.997760
0.998171
0.998582
0.998993
0.999404
0.997476
0.997867
0.998258
0.998650
0.999041
0.999432
0.997791
0.998134
0.998476
0.998818
0.999161
0.999503
(1,327,993)
(1,122,103)
(916,212)
(710,322)
(504,432)
(298,541)
-100
-125
-150
-175
-200
-250
-300
0.999790
1.000257
1.000725
1.001192
1.001659
1.002594
1.003529
0.999760
1.000294
1.000827
1.001361
1.001895
1.002962
1.004030
0.999769
1.000283
1.000796
1.001310
1.001824
1.002851
1.003878
0.999795
1.000251
1.000708
1.001164
1.001621
1.002534
1.003447
0.999805
1.000238
1.000671
1.001103
1.001536
1.002401
1.003266
0.999815
1.000226
1.000637
1.001048
1.001459
1.002281
1.003103
0.999824
1.000215
1.000607
1.000998
1.001389
1.002172
1.002955
0.999846
1.000188
1.000531
1.000873
1.001216
1.001901
1.002586
(92,651)
113,240
319,130
525,021
730,911
1,142,692
1,554,473
-12%
440,444,861
-23%
385,770,000
-20%
400,800,000
-10%
450,900,000
-5%
475,950,000
0%
501,000,000
5%
526,050,000
20%
601,200,000
Basis Point Shift
300
250
200
175
150
125
100
75
Redemptions/Subscriptions
Shares Outstanding
Shift Upon NAV = NAV - (WAM/365) * (Bp/10,000)
Dilution Upon NAV= (NAV + Change) / (1+ Change)
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
32.
PSFR Sensitivity Matrix
Top 10 Shareholders
Stress
Redemption
% of Fund
Shareholder 1
Shareholder 2
Shareholder 3
Shareholder 4
Shareholder 5
Shareholder 6
Shareholder 7
Shareholder 8
Shareholder 9
Shareholder 10
$
$
$
$
$
$
$
$
$
$
50,000,000.00
40,444,200.00
38,456,871.00
15,067,896.00
12,456,985.00
10,871,596.00
9,875,645.00
7,563,121.00
5,312,879.00
3,215,468.00
Stress Top 10
$
193,264,661.00
Total Fund Assets
$
500,248,500.00
10.00%
8.08%
7.69%
3.01%
2.49%
2.17%
1.97%
1.51%
1.06%
0.64%
No
Yes
No
No
Yes
No
No
Yes
No
No
38.63% No
100%
60,464,306.00
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
33.
Largest Five Day Redemption (%)
23%
Sample Press Release
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
34.
Sample Investment Pool Profile
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
35.
S&P’s Principal Stability Rated GIP Indices
S&P Rated
Government Investment Pool
Indices
S&P Rated
S&P
RatedGIP
GIPIndex/ALL
Index
(Week Ended
Ended August
Dec. 16,
(Week
30,2011)
2002)
S&P Rated GIP Index/Government
(Week Ended Dec 16, 2011)
S&P Rated GIP Index/G.P. Taxable
(Week Ended Dec 16, 2011)
7 Day
NET
Yield %
30 Day
NET
Yield %
7 Day
GROSS
Yield %
30 Day
GROSS
Yield %
Average
Maturity
(Days)
0.08%
1.61%
1.61%0.08%
1.86%0.20%
1.87%0.21%
4342
$102.4
$57.4
Billion
Billion
0.06%
0.06%
0.14%
0.15%
41
$33.5
Billion
0.09%
0.09%
0.22%
0.23%
43
$68.8
Billion
To View In Bloomberg: LGIP <Index> <Go>
Reported Weekly By Standard & Poor’s
Note: Indices comprised Of ‘AAAm’ Rated Government Investment Pools
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
36.
Sample of S&P Principal Stability Rated Fund Indices
S&P Rated Money Fund Indices (Week ended December 20, 2011)
Index Name
7 Day Net Yield %
30 Day Net Yield %
Avg. Maturity (days)
S&P 'AAAm' Money Fund Index/Government
0.01
0.01
46
S&P 'AAAm' Money Fund Index/Taxable
0.02
0.02
43
S&P 'AAAm' Money Fund Index/Tax-Free
0.02
0.02
36
AAAm European & Offshore PSFR Risk Metrics (as of September 30, 2011)
Index Name
7 Day Net
Yield %
30 Day Net
Yield %
Avg.
Maturity
(days)
Total Net Assets
(billions)
Credit Quality%
(A-1+/A-1)
S&P 'AAAm' European and
Offshore PSFR – EUR
0.90
0.89
21
EUR 161.90
73/27
S&P 'AAAm' European and
Offshore PSFR – GBP
0.53
0.52
30
GBP 122.50
70/30
S&P 'AAAm' European and
Offshore PSFR – USD
0.06
0.05
34
USD 308.40
81/19
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
37.
S&P’s Principal Stability Rated GIP Index – Quartile Rankings
7 Day
Ranking
Top Yield
30 Day
Low Yield
Top Yield
Low Yield
Gross Yields (%)
Top Quartile
0.31
0.25
0.31
0.24
Second Quartile
0.25
0.20
0.24
0.20
Third Quartile
0.20
0.15
0.20
0.15
Fourth Quartile
0.15
0.08
0.15
0.08
Net Yields (%)
Top Quartile
0.25
0.11
0.23
0.12
Second Quartile
0.11
0.05
0.12
0.05
Third Quartile
0.05
0.03
0.05
0.03
Fourth Quartile
0.03
0.01
0.03
0.01
(As of September 30, 2011)
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
38.
Recent Developments
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
39.
Impact of USA Rating Actions on S&P’s Pool Ratings

July 14, 2011: United States of America 'AAA/A-1+' Ratings Placed On CreditWatch Negative On
Rising Risk Of Policy Stalemate
(CreditWatch placement signals our view that, owing to the dynamics of the political debate on
the debt ceiling, there is at least a one-in-two likelihood that we could lower the long-term
rating on the U.S. within the next 90 days.)

July 15, 2011: 73 Fund Credit Quality Ratings Put On CreditWatch Negative Following
Sovereign Ratings CreditWatch Placement
NO impact to PSFR pools as the short term rating of the USA remains at A-1+

August 5, 2011: United States of America Long Term Rating Lowered To 'AA+' On Rising Debt
Burden And Political Risks; Outlook Negative
(The Negative Outlook means we could lower the long-term rating to 'AA' within the next two
years if we see that less reduction in spending than agreed to, higher interest rates, or new
fiscal pressures during the period result in a higher general government debt trajectory than
we currently assume in our base case.)

August 8, 2011: 73 Fund Credit-Quality Ratings Lowered And Removed From CreditWatch
Following U.S. Sovereign Downgrade
NO impact to PSFR pools as the short term rating of the USA remains at A-1+
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
40.
More Details on Pool Rating Changes
 We lowered our FCQRs on 73 of the 206 funds (including 14 GIPs) managed in the U.S.,
Europe, and Bermuda because of their significant exposures (generally greater than 50%) to
direct or indirect investments in U.S. Treasury and U.S. government agency securities.
 The ratings were lowered by up to two notches as determined by our fund credit-quality
matrix approach.
 Our FCQR methodology utilizes a fund credit-quality matrix to apply a set of credit factors for
each rating category (e.g., 'AAA', 'AA', 'A') and a set of credit scores for each FCQR category
(e.g. 'AAAf', 'AAf', 'Af'). The factors are based on our historical ratings stability and ratings
transition studies and do not differentiate between rating notches within a specific rating
category (e.g., the same factor is applied for exposure to 'AA+' securities as to 'AA' or 'AA-‘
securities).
 Because the probability of a rating transition and default decreases as a security nears
maturity, we evaluate investment-grade holdings that mature in 365 days or less in the matrix
at a lower credit factor, reducing the impact to the overall fund rating score. For example, a
portfolio comprised 60% of 'AA+' rated securities that mature in more than 365 days with the
remainder in 'AAA' rated securities would result in the FCQR category of 'AAf' according to
our fund credit-quality matrix approach.
 San Mateo (CA), Manatee County (FL), City of LA (CA) and Santa Barbara County (CA) have
since withdrawn their ratings
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
41.
Appendix
Additional Information on LGIP Ratings & S&P
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
42.
S&P’s Credit Rating Guides
To help raise awareness, S&P has published guides to credit ratings
essentials, performance and criteria
Additional resources are available @
www.UnderstandingRatings.com & www.AboutCreditRatings.com
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
43.
Principal Stability Fund Ratings Definitions (Effective January 5, 2010)
• A Standard & Poor's principal stability fund rating, also known as a "money
market fund rating," is a forward-looking opinion about a fixed income fund's
capacity to maintain stable principal (net asset value). When assigning a principal
stability rating to a fund, Standard & Poor's analysis focuses primarily on the creditworthiness of the
fund's investments and counterparties, and also its investments’ maturity structure and
management's ability and policies to maintain the fund's stable net asset value. Principal stability
fund ratings are assigned to funds that seek to maintain a stable or an accumulating net asset value.
• Generally, when faced with an unanticipated level of redemption requests during periods of high
market stress, the manager of any fund may suspend redemptions for up to five business days or
meet redemption requests with payments in-kind in lieu of cash. A temporary suspension of
redemptions or meeting redemption requests with distributions in-kind does not
constitute a failure to maintain stable net asset values. However, higher rated funds are
expected to have stronger capacities to pay investor redemptions in cash during times of high market
stress because they generally comprise shorter maturity and higher quality investments.
• Principal stability fund ratings, or money market fund ratings, are identified by
the 'm' suffix (e.g., ‘AAAm’) to distinguish the principal stability rating from a Standard & Poor's
traditional issue or issuer credit rating. A traditional issue or issuer credit rating reflects Standard &
Poor’s view of a borrower’s ability to meet its financial obligations. Principal stability fund ratings are
not commentaries on yield levels.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
44.
Diversification Subfactors
AAAm
AAm
Am
BBBm
5%
5%
5%
5%
Maximum per sovereign (i.e., national government)
entity rated 'AA-' or higher
100%
100%
100%
100%
Maximum per sovereign entity rated 'A-1' or 'A+' and
that matures in one business day
25%
25%
25%
25%
Maximum per sovereign entity rated 'A-1' or 'A+' and
that matures between two and five business days
10%
10%
10%
10%
Maximum per sovereign entity rated 'A-1' or 'A+' and
that matures in more than five business days
5%
5%
5%
5%
Maximum per bank rated 'A-1' or higher or 'A+' or
higher for uncollateralized overnight bank deposits,
including uninvested cash
10%
10%
10%
10%
Maximum per issuer (including debt guaranteed by the same
issuer)--except for the items below
Tiered maximums for investments that are fully
(100%) collateralized or overcollateralized (more than
100%)
See charts 2, 3 and 4 in “Methodology: Principal Stability
Fund Ratings Criteria” for details
Maximum exposure per sovereign government
related/guaranteed entity rated 'AA-' or higher¶¶
33%
50%
67%
75%
Maximum exposure to another Standard & Poor's
rated fund
10%
15%
20%
25%
¶¶GRE or government-guaranteed investments rated 'AA-' or higher with final maturities of 30 days or less are excluded from these limits.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
45.
Maturity Subfactors
AAAm
AAm
Am
BBBm
Maximum WAM(R) (days)§
60
70
80
90
Maximum WAM(F) (days)§^
90
100
110
120
Maximum final maturity per fixed-rate
investment, nonsovereign government
floating-rate investment, and sovereign
floating-rate investments rated below
'AA-'
13 months
(397 days)
13 months
(397 days)
13 months
(397 days)
13 months
(397 days)
Maximum final maturity per sovereign
government (including sovereign
government related/guaranteed)
floating-rate security rated 'AA-' or
higher
Two years
(762 days)
Three years
(1,127 days)
Four years
(1,492 days)
Five years
(1,857 days)
§ The maximum WAM(R) and WAM(F) limits may be reduced for funds with certain characteristics (such as limited operating history
or start-up funds, small asset size, a concentrated shareholder base, or a new shareholder base with uncertain liquidity needs).
^ May be adjusted upward by 30 days if invested only in government/GSE floaters rated 'AA-' or higher. If a fund invests in a
combination of government floaters rated 'AA-' or higher and nongovernment floating-rate instruments (or sovereigns rated below 'AA'), the maximum is based on the weighted average of exposures to each type of floater.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
46.
Portfolio Credit Quality Metrics
Minimum 'A-1+' and 'A-1'
investments maturing
within five business days
Maximum 'A-1'
investments maturing in
more than five business
days**
Maximum exposure to
unrated municipal bonds
secured by escrow account
AAAm
AAm
Am
BBBm
50%
20%
0%
0%
50%
25%
80%
33%
100%
40%
Imputing Short-Term Ratings
From Long-Term Ratings
100%
50%
Maximum exposure to
municipal securities rated
only by Moody's or Fitch¶
15%
20%
25%
30%
Maximum exposure to
unrated credit-enhanced
variable-rate demand
obligations (VRDOs)
10%
15%
20%
25%
Long-Term Rating
Imputed Short-Term Rating
'AAA' through 'AA-'
'A-1+'
'A+'
'A-1'
'A' or lower
"Higher-risk investment"
** Exposures to securities rated below 'A-1' are "higher-risk investments.“
•¶ This limit does not apply to securities that possess a direct pay letter of credit that Standard & Poor's rates 'A-1+' or 'A-1'.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
47.
Sample MMF Portfolio – Maturity Calculations
ABC MONEY MARKET FUND
31-Mar-10
A
B
C
D
E
F
G
Security Description
Market Value
Days to
Maturity
Maturity
Date
Days to
Reset
Next Reset
Date
%
1
04/01/10
REPO
$
3,500,000,000
COPORATE BOND
$
300,000,000
244
11/30/10
COPORATE BOND
$
250,000,000
334
02/28/11
AGENCY
$
500,000,000
244
11/30/10
60
05/30/10
7.52%
AGENCY
$
1,000,000,000
183
09/30/10
30
04/30/10
15.04%
AGENCY
$
350,000,000
157
09/04/10
5.26%
TREASURY
$
750,000,000
91
06/30/10
11.28%
$
6,650,000,000
Total Fund:
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
48.
52.63%
91
06/30/10
4.51%
3.76%
100.00%
Money Market Fund Industry Events on ‘Richter Scale’
10
9
8
10-Jan
7
Jun-96
6
Jul-83
5
Feb-70
Mar-86
Feb-91
4
3
2
* Dates noted on graph indicate regulatory rule changes
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
49.
Jul-09
Jul-07
Jul-05
Jul-03
Jul-01
Jul-99
Jul-97
Jul-95
Jul-93
Jul-91
Jul-89
Jul-87
Jul-85
Jul-83
Jul-81
Jul-79
Jul-77
Jul-75
Jul-73
Jul-71
0
Jul-69
1
Noteworthy Events in the Money Market Industry
Feb-70
Jul-83
Mar-86
Feb-91
May-94
Jun-94
Dec-94
Jun-96
Jan-97
Aug-99
Apr-01
Aug-07
Sep-07
Oct-07
Nov-07
Feb-08
Mar-08
Sep-08
Oct-08
Nov-08
Dec-08
Jan-09
Mar-09
Jul-09
Jan-10
4.0
5.5
4.0
4.0
6.0
6.0
5.5
4.0
5.5
5.0
5.5
5.5
5.5
6.5
4.0
4.5
4.0
10.0
4.0
4.0
4.0
4.0
4.0
5.5
5.0
First MMF Created
SEC Adopts Rule 2a-7
SEC Amends Rule 2a-7
SEC Amends Rule 2a-7
Derivatives in MMFs
Community Bankers US Government Fund breaks the buck
Orange County Bankruptcy
SEC Amends Rule 2a-7
Mercury Finance CP Default
General American Funding Agreement Problems
PG&E Default (CA Energy Crisis)
XABCP
SIV-lites
SIVs
FL SBA LGIP
Auction Rate Securities, Bond Insurers
Bear Stearns
Lehman Bankrupt; Reserve Primary Fund ‘Breaks the Buck’ & Govt Gty
Lehman/Reserve Fallout
Lehman/Reserve Fallout
Very Low Yields
G30 Report on Financial Reform
ICI MMF Working Group Report
SEC Propose Money Market Fund Reforms
SEC Adopts Amendments to Rule 2a-7
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
50.
Standard & Poor’s Initiatives
Action Steps & Initiatives
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
51.
Key Leadership Actions Taken Since February 2008*
Governance, Analytics, Education, Information
- Incorporated stability as a ratings factor
Strengthen
the ratings
process
Better serve
the markets
- Enhanced criteria used to rate U.S. RMBS, CMBS
and CDOs
- Launched new tools for surveillance
- Introduced hypothetical stress scenarios to be used as
benchmarks for calibrating criteria across different
sectors and over time
- Established “what if” scenarios for the majority of
rated structured finance securities
- Re-launched standardandpoors.com providing easy
access to ratings, criteria, reports of ratings
performance, updates on leadership actions and
related information
- Issued RFCs on non-default risks focusing on
liquidity, volatility, correlation and recovery
- Published “Guide to Credit Ratings Essentials”, “Guide
to Ratings Performance” and “Guide to Credit Ratings
Criteria”
- Published Landmark Deal reports
Enhance
Governance
- Separated the criteria management and development,
quality assurance and policy governance groups from
the analytic teams within ratings
- Implemented ‘look-back’ reviews of analysts work
whenever one leaves to work for an issuer
- Instituted an analyst rotation program
- Created a Model Quality Review group
- Instituted a new credit analyst certification
program and increased analyst continuing
education requirements
- Added the “SF” symbol to all ratings on structured
finance instruments on a global basis (to comply
with a European Union regulation)
- Launched Recovery Analytics for U.S. RMBS,
CLOs and issued a market feedback request
(MFR) for CMBS recovery analytics
- Established new leadership in ratings criteria,
structured finance, compliance and quality review
- New personnel and resources in compliance
functions and enhanced global compliance training
- Established the Enterprise Risk Oversight
Committee
*Representative listing of Standard & Poor’s Leadership Actions. For more information please visit the Leadership Actions section on standardandpoors.com.
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
52.
Standard & Poor’s Globally
•
•
•
150 years of experience
Global office network in 23 Countries and markets. European operations
established in 1984, with offices in London, Frankfurt, Paris, Madrid, Milan,
Stockholm, Moscow, Dubai, Johannesburg and Tel Aviv. Asia Pacific
operations commenced 1986 with an office in Tokyo followed by Melbourne,
Hong Kong, Singapore, Taipei and Mumbai
Over 1,300 credit ratings analysts globally
Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor’s.
53.
www.standardandpoors.com
Copyright © 2011 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 non-public 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
Permission
to reprint
or distribute
anyS&P
content
from this
requires theAdditional
prior written
approval
of Standard
Poor’s.
distributed
through other
means,
including via
publications
andpresentation
third-party redistributors.
information
about
our ratings&fees
is available at www.standardandpoors.com/usratingsfees.
54.