23-D-1618
March 5, 2024

Japan Credit Rating Agency, Ltd. (JCR) announces the following credit rating.

Aozora Bank, Ltd. (security code: 8304)<Outlook Change>
Long-term Issuer Rating:
Outlook:Afrom Stable to Negative

Rationale(1) The business size of Aozora Bank, Ltd. (the “Bank”), with a fund volume of approximately 5.6 trillion
yen, is small compared to major banks in Japan; however, has strengths in expertize in structured
finance in the fields of real estate and LBO. Under the each group of institutional banking, structured
finance, international business, market and customer relations, it is pushing ahead with “Aozora’s
Strategic Investments Business” that supports growth of corporations by establishing relations
through investment and loans.
(2) The rating had been supported by the business foundation originated by multiple businesses withcompetitive edge, sound asset quality, reasonable earnings capacity and capital adequacy. However,fundamental earning capacity has declined with a major reason of deteriorated profit/loss of securities.
On the backdrop of reporting a deficit due to a large amount of credit costs and a decline in adjusted
core capital ratio caused by expansion of valuation losses on securities, the adjusted core capitalratio declined and is pale for a bank falling under the A rating category. JCR views that earnings
capacity and capital adequacy ratio will improve going forward; but revised the rating outlook from
Stable to Negative because it may take time for recovering to the previous level. Since theperformance of investment business has been steady, JCR will closely watch whether it can improvethe earnings capacity and capital adequacy ratio early.
(3) The Bank’s fundamental earnings capacity has declined attributable to deteriorated profit/loss of
securities, constraint on sales of structured bonds and other factors. In addition, the Bank revised thefull year performance forecast to a net loss of 28 billion yen for the fiscal year ending March 2024
(FY2023) because of the credit costs for real estate nonrecourse loans for offices in the U.S. andlosses on sales of securities with unrealized losses. On the other hand, the investment banking
business is steady centering on the institutional business, structured finance and international
business, supporting the overall performance. JCR will watch whether the Bank can recover theearnings capacity early through full scale earnings contribution of GMO Aozora Net Bank, Ltd., aconsolidated subsidiary, in addition to an improvement in profit/loss of securities and reinforcementof the retail business.
(4) As for loan assets, the Bank is susceptible to the external environment due to high credit
concentration in specific fields such as real estate finance in Japan and abroad, and overseas
corporate loans. In FY2023, as a result of deterioration in the U.S. real estate market for offices, theBank reviewed the valuation of nonrecourse loans in the said area and recorded a large amount ofcredit costs. While risk of incurring additional losses receded through conducting conservativeevaluation this time, the U.S. real estate market for offices is still unforeseeable. Therefore, JCR will
watch the future trend.
(5) In securities investment, valuation loss on other securities available-for-sale reached 81.5 billion yen(including hedge positions) at the end of December 2023 due to the impact of rising overseas interest
rates, and the amount is worth slightly below 20% of the core capital. The Bank has started to workon reconstruction of the portfolio as shown that it sold some of securities with unrealized losses in thesecond half of FY2023. JCR will watch the progress in portfolio reconstruction and trends in an
improvement in profit/loss and valuation losses of securities.

1/2
Copyright © Japan Credit Rating Agency, Ltd. All Rights Reserved.

(6) Capital adequacy ratio leaves room for improvement against the rating. Adjusted core capital ratio
considering valuation losses on other securities available-for-sale, etc. remained in the lower 7%
range at the end of December 2023. From a medium-term perspective, JCR views that the adjusted
core capital ratio will be recovering through improving earnings capacity and controlling risk-weighted
assets, and will watch their progress. There are no particular concerns over the liquidity. Although thesize of assets in foreign currencies is large, the foreign currency procurement structure is stablethrough diversifying the financing methods.
Tsuyoshi Ohishi, Kenta Asada

RatingIssuer: Aozora Bank, Ltd.
<Outlook Change>

Long-term Issuer Rating: A

Outlook: Negative

Rating Assignment Date: February 29, 2024
The assumptions for the credit ratings and the definitions of the rating symbols are published as "Types of Credit Ratings and Definitionsof Rating Symbols" (January 6, 2014) in Information about JCR Ratings on JCR's website (https://www.jcr.co.jp/en/).
Outline of the rating methodology is shown as "JCR's Rating Methodology" (February 1, 2024) and "Banks" (October 1, 2021)
in Information about JCR Ratings on JCR's website (https://www.jcr.co.jp/en/).
The rating stakeholder participated in the rating process of the aforementioned credit ratings.

Japan Credit Rating Agency, Ltd.
Jiji Press Building, 5-15-8 Ginza, Chuo-ku, Tokyo 104-0061, Japan
Tel. +81 3 3544 7013, Fax. +81 3 3544 7026
Information herein has been obtained by JCR from the issuers and other sources believed to be accurate and reliable. However, because of the possibility of human or mechanical error as well as other factors,
JCR makes no representation or warranty, express or implied, as to accuracy, results, adequacy, timeliness, completeness or merchantability, or fitness for any particular purpose, with respect to any suchinformation, and is not responsible for any errors or omissions, or for results obtained from the use of such information. Under no circumstances will JCR be liable for any special, indirect, incidental orconsequential damages of any kind caused by the use of any such information, including but not limited to, lost opportunity or lost money, whether in contract, tort, strict liability or otherwise, and whether
such damages are foreseeable or unforeseeable. JCR's ratings and credit assessments are statements of JCR's current and comprehensive opinion regarding redemption possibility, etc. of financial obligations
assumed by the issuers or financial products, and not statements of opinion regarding any risk other than credit risk, such as market liquidity risk or price fluctuation risk. JCR's ratings and credit assessments
are statements of opinion, and not statements of fact as to credit risk decisions or recommendations regarding decisions to purchase, sell or hold any securities such as individual bonds or commercial paper.
The ratings and credit assessments may be changed, suspended or withdrawn as a result of changes in or unavailability of information as well as other factors. JCR receives a rating fee paid by issuers for
conducting rating services in principle. JCR retains all rights pertaining to this document, including JCR's rating data. Any reproduction, adaptation, alteration, etc. of this document, including such rating
data, is prohibited, whether or not wholly or partly, without prior consent of JCR.
JCR is registered as a "Nationally Recognized Statistical Rating Organization" with the U.S. Securities and Exchange Commission with respect to the following four classes. (1) Financial institutions, brokers
and dealers, (2) Insurance Companies, (3) Corporate Issuers, (4) Issuers of government securities, municipal securities and foreign government securities.
JCR publishes its press releases regarding the rating actions both in Japanese and in English on the same day. In case that it takes time to translate rating rationale, JCR may publicize the summary version,
which will be replaced by the full translated version within three business days. (Regarding Structured Finance products, JCR only publicize the summary version in English.)

2/2
Copyright © Japan Credit Rating Agency, Ltd. All Rights Reserved.

I n f o r m at i o n D i s c l o s u r e F o r mJapan Credit Rating Agency, Ltd.

Disclosure Required by Paragraph (a)(1)(ii) of Rule 17g-7

1

Issuer:Aozora Bank, Ltd.

Rating Publication
Date:

March 5, 2024

The Symbol, Number, or Score in the Rating Scale used to Denote Credit Rating Categories andNotches and, the Identity of the Obligor or the Identity and a Description of the Security or Money
Market Instrument as Required by Paragraph (a)(1)(ii)(A) of Rule 17g-7
 Please see the news release. If the credit rating is a private rating, please see the report for private
rating.

2

The version of the procedure or methodology used to determine the credit rating; as Required by
Paragraph (a)(1)(ii)(B) of Rule 17g-7
 Please see the news release. If the credit rating is a private rating, please see the report for private
rating.

3

The Main Assumptions and Principles used in Constructing the Procedures and Methodologies used
to Determine the Credit Rating as Required by Paragraph (a)(1)(ii)(C) of Rule 17g-7
 The credit rating methodology assumes, in principle, to be applied to assess the likelihood of a given
debt payment in light of its issuer’s condition and business environment, etc. in the relevant future.
There is certain limitation, however, in the time horizon that the rating foresees.
 The credit rating methodology assumes, in principle, that the factors posted in the below areparticularly important for such likelihood to be determined, and that the rating determination is madeby evaluating each of them not only quantitatively but also employing qualitative analyses.

A) Business Bases
The likelihood of a given debt payment is highly conditional to its issuer’s business bases - how they
can be maintained/ expanded into the future and thereby secure earnings and cash flows in adequacy
and in a sustainable way.
B) Financial Grounds and Asset Quality
The likelihood of debt payment is highly dependent on the degree of the issuer’s indebtedness and loss
absorption capacity in terms of equity capital. Also notable is that a financial institution might see asignificant loss of financial grounds as a result of changes in value of the assets under its possession.
C) Liquidity Positions
The likelihood of debt payment is highly dependent on the adequacy of the issuer’s cash and othersources of repayment (liquidity positions).

1/5D) Related Parties’ Status and Stance of Support/ Assistance for the Issuer
The likelihood of debt payment is affected one way or the other by the issuer’s related parties such as
parent company, subsidiary, guarantor, and the government of the issuer’s business domicile, etc. - bytheir own conditions and/ or position of support/ assistance for the issuer.
E) Order of Seniority in Debt Payment
The likelihood of debt payment can be different between given debts of the same issuer. The likelihoodof debt payment for an individual debt is dependent on the issuer’s discretion, and/ or its rank relative
to other debts of the same issuer in the order of seniority in principal/ interest payment which isdetermined by design as financial product or by laws, etc.

4

The Potential Limitations of the Credit Rating as Required by Paragraph (a)(1)(ii)(D) of Rule 17g-7
 The credit rating herewith presented by JCR is its summary opinion with regard to the likelihood ofgiven debt payment and hence not necessarily a perfect representation of such likelihood. The credit
rating is not intended to estimate the probability of default or the loss on given default, either.
 The objective of the credit rating herewith presented does not include any concerns other than thelikelihood of debt payment, such as risks of price changes, market liquidity, etc.
 The credit rating herewith presented is necessary to be reviewed along with possible changes of theissuer of rated objects in its business performance and/ or circumstances which include regulatoryenvironment, and hence subject to possible alteration.

5

Information on the Uncertainty of the Credit Rating as Required by Paragraph (a)(1)(ii)(E) of Rule
17g-7
 The information used for the determination of credit rating as herewith presented is obtained by JCR
from the issuer of rated objects and other sources that JCR trusts in terms of accuracy and reliability
but possibly contains errors due to human, non-human or other causes. Consequently, the credit rating
determined on the grounds of such information does not constitute, explicitly or implicitly, any
representation or warrant of JCR on the information itself or any consequences of its use in terms ofaccuracy, relevance, timeliness, wholeness, market value, or usefulness for any specific purposes.

6

Use of Due Diligence Services of a Third Party in Taking the Rating Action as Required by Paragraph(a)(1)(ii)(F) of Rule 17g-7
 There is no use of any third-party due diligence service in the determination of the credit ratingherewith presented.

7

Use of Servicer or Remittance Reports to Conduct Surveillance of the Credit Rating Required by
Paragraph (a)(1)(ii)(G) of Rule 17g-7
 There is no use of any servicer or remittance report to conduct surveillance of the credit rating herewithpresented.

8

The Types of Data Relied Upon for the Purpose of Determining the Credit Rating as Required by
Paragraph (a)(1)(ii)(H) of Rule17g-7

2/5

 The information posted in the below, which includes data, is used for the determination of the credit
rating herewith presented.
A) Audited financial statements presented by the rating stakeholders
B) Explanations of business performance, management plans, etc. presented by the rating stakeholders

9Overall assessment of the Quality of Information Available and Considered in Determining theCredit Rating as Required by Paragraph (a)(1)(ii)(l) of Rule 17g-7
 JCR holds its basic policies for securing the quality of information as a base of due diligence for thedetermination of credit ratings. The information used as a base for the determination of credit ratingherewith presented satisfies such policies, which include the audit by an independent auditor, thewarranty made by the issuer, the publication by the issuer, some independent media or, otherwise, JCR
analyst’s scrutiny, etc.
 JCR sees no particular weakness in the quality of information used for the determination of the credit
rating herewith presented as compared to the information used in other cases of the credit rating forcomparable issuers or ratable objects.
 If the credit rating is an Indication, please see the report for Indication.

10 Information Relating to Conflicts of Interest as Required by Paragraph (a)(1)(ii)(J) of Rule 17g-7
 JCR receives payment of compensation for the determination of the credit rating herewith presented
from either one of those parties who are issuer, underwriter, depositor or sponsor.
 JCR received in the last fiscal year in the past payment of compensation from the same party for any
kind of JCR’s service other than the determination of public or private credit rating, such as one in the
ancillary business.

or Measure of the Potential Volatility of the Credit Rating as Required by Paragraph
11 Explanation(a)(1)(ii)(K) of Rule 17g-7
A) Business Bases
The credit rating is subject to alteration if there is improvement or deterioration of the issuer’s businessbases, since its revenue, etc. may improve or deteriorate by the change in its business management
policies, clients’ preferences, competitive situation, or a technological innovation. The resultant
alteration of the credit rating is usually by a notch, with possibility of a few notches if and when thechange in the business bases is large.
B) Financial Grounds and Asset Quality
The credit rating is subject to alteration if the issuer increases/ decreases its debt/ capital or vice versa
and thereby makes its individual debt payment liability less or more bearable and its loss absorption
capacity into the future decreased or increased. Also, the changes in the quality of asset under theissuer’s holding may affect the credit rating, since such changes could raise or lower the likelihood of
future loss of the issuer’s financial grounds. The resultant alteration of the credit rating is usually by anotch, with possibility of a few notches if and when the change in the financial grounds and/ or asset
quality is large.
C) Liquidity Positions
The credit rating is subject to alteration if there is a change in the issuer’s financial management policy
or in the relations with fund procurement sources and the change thereby makes its liquidity positions
improve or deteriorate. The resultant alteration of the credit rating is usually by a notch, with possibilityof a few notches if and when the change is large.

3/5D) Related Parties’ Status and Stance of Support/ Assistance for the Issuer
The credit rating is subject to alteration if there is a change in the issuer’s parent company or subsidiary,guarantor or other provider of credit enhancement, or the government of the issuer’s business domicile,or other related parties’ own conditions and/ or position of support/ assistance for the issuer, and thechange thereby makes its business bases, financial grounds and/ or liquidity positions improve or
deteriorate, and/ or making the effectiveness of guarantee and other credit enhancement improve or
deteriorate. The resultant alteration of the credit rating is usually a notch, with possibility of a few
notches if and when the change is large.
E) Order of Seniority in Debt Payment and Non-Payment Forgiven by Contract
The credit rating is subject to alteration if there is a change in the rated debt’s status in the order ofseniority relative to other debts caused by the improvement/ deterioration of the issuer’s financial
condition. The resultant alteration of the credit rating is usually a notch, with possibility of a few
notches if and when the change is large. Also, in case of the financial products for which non-payment
of interest/ principal is contractually permissible, the credit rating is subject to alteration if and when
the likelihood of such non-payment is projected to increase or decrease. The resultant alteration of thecredit rating could be by a notch but often as much as a few notches.
F) Rise and Fall in General Economy and Markets
The credit rating is subject to alteration if there is a rise/ fall in the general economy and/ or the markets
inducing the issuer’s revenues/ expenses to increase/ decrease and vice versa, etc. The resultant
alteration of the credit rating is usually by a notch, with possibility of a few notches if and when thechange is exceptionally large.
G) Various Events
The credit rating is subject to alteration on occurrence of various events, such as change in the issuer’s
major shareholders, M&A and other organizational change, accident, violation of the law, litigation,legal/ regulatory change, natural disaster, etc., which are unforeseeable at the time when the credit
rating is determined, causing a significant change on the issuer’s business bases, financial grounds, etc.
The resultant alteration of the credit rating could be by a notch but more often than not as much as afew notches.

12

Information on the Content of the Credit Rating, Including the Historical Performance of the Credit
Rating and the Expected Probability of Default and the Expected Loss in the Event of Default as
Required by Paragraph (a)(1)(ii)(L) of Rule 17g-7
 Historical records of the credit rating herewith presented are posted in the end of this paper.
 The credit rating herewith presented by JCR is its summary opinion with regard to the likelihood ofgiven debt payment and hence not necessarily a perfect representation of such likelihood. The credit
rating is not intended to estimate the probability of default or the loss on given default, either.
 Facts of the probability of default are posted as Form NRSRO Exhibit 1 on the JCR website under the
URL:
https://www.jcr.co.jp/en/service/company/regu/nrsro/on the Sensitivity of the Credit Rating to Assumptions Made as Required by Paragraph
13 Information(a)(1)(ii)(M) of Rule 17g-7
A) Business Bases
The credit rating herewith presented could be changed if and when the assumptions made at the time ofits determination turn out to be inaccurate with regard to the issuer’s business bases and powers ofearning or cash flow generation, etc. The resultant change of the credit rating is most likely by a notch,
as JCR speculates, but possibly as much as a few notches if the development is rapid in improvement or
deterioration of the issuer’s business bases on some drastic change in the operational environments, etc.
B) Financial Grounds and Asset Quality
The credit rating herewith presented could be changed if and when the assumptions made at the time ofits determination turn out to be inaccurate with regard to the issuer’s financial grounds and asset
quality. The resultant change of the credit rating is most likely by a notch, as JCR speculates, but
4/5

possibly as much as a few notches if the development is rapid in improvement or deterioration of theissuer’s financial grounds and/ or asset quality on some drastic change in its business bases.

C) Liquidity Risks
The credit rating herewith presented could be changed if and when the assumptions made at the time ofits determination turn out to be inaccurate with regard to the issuer’s liquidity positions. The resultant
change of the credit rating is most likely by a notch, as JCR speculates, but possibly as much as a few
notches if the development is rapid in improvement or deterioration of the issuer’s liquidity positions
on some drastic change in its financial management policy or relations with fund procurement sources,
etc.
D) Related Parties’ Status and Stance of Support/ Assistance for the Issuer
The credit rating herewith presented could be changed if and when the assumptions made at the time ofits determination turn out to be inaccurate with regard to the issuer’s parent company or subsidiaries,
guarantor or other providers of credit enhancement, the government of the issuer’s business domicile orother related parties’ status and stance of support/ assistance for the issuer. The resultant change of thecredit rating is most likely by a notch, as JCR speculates, but possibly as much as a few notches if there
is a major change on the part of related parties, such as replacement, disappearance, some drastic
improvement/ deterioration of financial grounds/ balances, etc.
E) Rise and Fall in General Economy and Markets
The credit rating herewith presented could be changed if and when the assumptions made at the time ofits determination turn out to be inaccurate with regard to the prospects of general economy and markets.
JCR expects the change should be most likely by a notch but could be as much as a few notches, should
the economy or the markets change so greatly.

on the Representations, Warranties, and Enforcement Mechanisms of an Asset-backed
14 Information
Security as Required by Paragraph (a)(1)(ii)(N) of rule 17g-7
 The credit rating herewith presented is not for an ABS product, and hence no relevant issue.

Japan Credit Rating Agency, Ltd.
Jiji Press Building, 5-15-8 Ginza, Chuo-ku, Tokyo 104-0061, Japan
Tel. +81 3 3544 7013, Fax. +81 3 3544 7026

ormation herein has been obtained by JCR from the issuers and other sources believed to be accurate and reliable. However, because of the possibility of human or mechanical error as well as
er factors, JCR makes no representation or warranty, express or implied, as to accuracy, results, adequacy, timeliness, co mpleteness or merchantability, or fitness for any particular purpose,h respect to any such information, and is not responsible for any errors or omissions, or for results obtained from the us e of such information. Under no circumstances will JCR be liable for
special, indirect, incidental or consequential damages of any kind caused by the use of any such information, including but not limited to, lost opportunity or lost money, whether in contract,, strict liability or otherwise, and whether such damages are foreseeable or unforeseeable. JCR’s ratings and credit assessments are statements of JCR’s current and comprehensive opinion
arding redemption possibility, etc. of financial obligations assumed by the issuers or financial products, and not statements of opinion regarding any risk other than credit risk, such as market
uidity risk or price fluctuation risk. JCR’s ratings and credit assessments are statements of opinion, and not statements of fact as to credit risk decisions or recommendations regarding decisions
purchase, sell or hold any securities such as individual bonds or commercial paper. The ratings and credit assessments may be changed, suspended or withdrawn as a result of changes in or
vailability of information as well as other factors. JCR retains all rights pertaining to this document, including JCR’s rating data. Any reproduction, adaptation, alteration, etc. of this document,
uding such rating data, is prohibited, whether or not wholly or partly, without prior consent of JCR.

R is registered as a "Nationally Recognized Statistical Rating Organization" with the U.S. Securities and Exchange Commission with respect to the following fo ur classes. (1) Financial
itutions, brokers and dealers, (2) Insurance Companies, (3) Corporate Issuers, (4) Issuers of government securities, municipal securities and foreign government securities.

5/5

The Historical Performance of the Credit Rating
Issuer Name

Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.
Aozora Bank, Ltd.

Issue Name

Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)
Issuer(Long-term)

1/1

Publication Date

RatingOutlook/Direction

March 14, 2003
March 11, 2004
March 7, 2005
June 28, 2006
December 7, 2007
November 14, 2008
December 17, 2008
February 12, 2009
November 26, 2010
December 8, 2011
February 21, 2013
February 26, 2014
February 27, 2015
May 2, 2016
May 25, 2017
March 5, 2018
February 19, 2019
February 14, 2020
February 25, 2021
February 14, 2022
March 7, 2023

AAAA
A
#A
ABBB+
BBB+
BBB+
BBB+
AAAAA
A
A
A
A
A

StableStableNegative
Negative
Negative
StableStablePositive
StableStableStableStableStableStableStableStableStableStableAttachment

Attestation Required by Paragraph (a)(1)(iii) of Rule 17g-7

I, Tomohiro Miyao, have responsibility to this Rating Action and to the best of my knowledge:

A) No part of the credit rating was influenced by any other business activities.
B) The credit rating was based solely upon the merits of the obligor, security, or money market
instrument being rated.
C) The credit rating was an independent evaluation of the credit risk of the obligor, security, or
money market instrument.

Tomohiro Miyao
General Manager of Financial Institution Rating Department

Japan Credit Rating Agency, Ltd.
Jiji Press Building, 5-15-8 Ginza, Chuo-ku, Tokyo 104-0061, Japan
Tel. +81 3 3544 7013, Fax. +81 3 3544 7026

mation herein has been obtained by JCR from the issuers and other sources believed to be accurate and reliable. However, because of the possibility of human or mechanical error as well asfactors, JCR makes no representation or warranty, express or implied, as to accuracy, results, adequacy, timeliness, co mpleteness or merchantability, or fitness for any particular purpose,
espect to any such information, and is not responsible for any errors or omissions, or for results obtained from the us e of such information. Under no circumstances will JCR be liable for
ecial, indirect, incidental or consequential damages of any kind caused by the use of any such information, including but not limited to, lost opportunity or lost money, whether in contract,
rict liability or otherwise, and whether such damages are foreseeable or unforeseeable. JCR’s ratings and credit assessments are statements of JCR’s current and comprehensive opinion
ing redemption possibility, etc. of financial obligations assumed by the issuers or financial products, and not statements of opinion regarding any risk other than credit risk, such as market
ty risk or price fluctuation risk. JCR’s ratings and credit assessments are statements of opinion, and not statements of fact as to credit risk decisions or recommendations regarding decisions
chase, sell or hold any securities such as individual bonds or commercial paper. The ratings and credit assessments may be changed, suspended or withdrawn as a result of changes in or
ilability of information as well as other factors. JCR retains all rights pertaining to this document, including JCR’s rating data. Any reproduction, adaptation, alteration, etc. of this document,
ing such rating data, is prohibited, whether or not wholly or partly, without prior consent of JCR.

s registered as a "Nationally Recognized Statistical Rating Organization" with the U.S. Securities and Exchange Commission with respect to the following fo ur classes. (1) Financial
tions, brokers and dealers, (2) Insurance Companies, (3) Corporate Issuers, (4) Issuers of government securities, municipal securities and foreign government securities.