Rating Action: Moody’s affirms five and downgrades five classes of MSC 2012-C4Global Credit Research – 21 Dec 2021Approximately $340.8 million of structured securities affectedNew York, December 21, 2021 — Moody’s Investors Service, Inc. (“Moody’s”) has affirmed the ratings on five classes and downgraded the ratings on five classes in Morgan Stanley Capital I Trust 2012-C4 (“MSC 2012-C4”), Commercial Mortgage Pass-Through Certificates, Series 2012-C4, as follows:Cl. A-4, Affirmed Aaa (sf); previously on Feb 9, 2021 Affirmed Aaa (sf)Cl. A-S, Affirmed Aaa (sf); previously on Feb 9, 2021 Affirmed Aaa (sf)Cl. B, Affirmed Aa2 (sf); previously on Feb 9, 2021 Affirmed Aa2 (sf)Cl. C, Downgraded to Baa1 (sf); previously on Feb 9, 2021 Affirmed A2 (sf)Cl. D, Downgraded to B1 (sf); previously on Feb 9, 2021 Downgraded to Ba2 (sf)Cl. E, Downgraded to Caa3 (sf); previously on Feb 9, 2021 Downgraded to Caa1 (sf)Cl. F, Downgraded to C (sf); previously on Feb 9, 2021 Downgraded to Ca (sf)Cl. G, Affirmed C (sf); previously on Feb 9, 2021 Downgraded to C (sf)Cl. X-A*, Affirmed Aaa (sf); previously on Feb 9, 2021 Affirmed Aaa (sf)Cl. X-B*, Downgraded to Caa3 (sf); previously on Feb 9, 2021 Downgraded to Caa2 (sf)*Reflects Interest-Only ClassesRATINGS RATIONALEThe ratings on three P&I classes were affirmed because of the credit support and the transaction’s key metrics, including Moody’s loan-to-value (LTV) ratio and Moody’s stressed debt service coverage ratio (DSCR), are within acceptable ranges.The ratings on four P&I classes were downgraded primarily due to an increase in expected losses and interest shortfall risks due to the further decline in performance of the specially serviced loan, the Shoppes at Buckland Hills loan (30.5% of the pool). The loan is secured by a regional mall with significant declines in performance and a year-end 2020 NOI DSCR below 1.00X. The loan has a scheduled maturity date in March 2022 and a receiver has taken over management of the mall with the ultimate resolution strategy to stabilize and sell the property. As of the November 2021 remittance statement an appraisal reduction of 25% has been recognized on this loan since no updated appraisal value has been reported. Moody’s anticipates interest shortfalls may increase from their current levels due the performance of this loan. Furthermore, the pool faces increased refinance risk as all the remaining loans mature by March 2022.The rating on Cl. G was affirmed because the ratings are consistent with Moody’s expected loss.The rating on one IO class was affirmed based on the credit quality of the referenced classes.The rating on one IO class was downgraded due to a decline in the credit quality of its referenced classes.Today’s action has considered how the coronavirus pandemic has reshaped the US economic environment and the way its aftershocks will continue to reverberate and influence the performance of commercial real estate. We expect the public health situation to improve as vaccinations against COVID-19 increase and societies continue to adapt to new protocols. Still, the exit from the pandemic will likely be bumpy and unpredictable and economic prospects will vary. Stress on commercial real estate properties will be most directly stemming from declines in hotel occupancies (particularly related to conference or other group attendance) and declines in foot traffic and sales at certain retail properties.We regard the coronavirus outbreak as a social risk under our ESG framework, given the substantial implications for public health and safety.Moody’s rating action reflects a base expected loss of 21.4% of the current pooled balance, compared to 10.4% at Moody’s last review. Moody’s base expected loss plus realized losses is now 8.2% of the original pooled balance, compared to 7.4% at the last review. Moody’s provides a current list of base expected losses for conduit and fusion CMBS transactions on moodys.com at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS:The performance expectations for a given variable indicate Moody’s forward-looking view of the likely range of performance over the medium term. Performance that falls outside the given range can indicate that the collateral’s credit quality is stronger or weaker than Moody’s had previously expected.Factors that could lead to an upgrade of the ratings include a significant amount of loan paydowns or amortization, an increase in the pool’s share of defeasance or an improvement in pool performance.Factors that could lead to a downgrade of the ratings include a decline in the performance of the pool, an increase in realized and expected losses from specially serviced and troubled loans or interest shortfalls.METHODOLOGY UNDERLYING THE RATING ACTIONThe principal methodology used in rating all classes except interest-only classes was “Large Loan and Single Asset/Single Borrower Commercial Mortgage-Backed Securitizations Methodology” published in November 2021 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_1250766. The methodologies used in rating interest-only classes were “Large Loan and Single Asset/Single Borrower Commercial Mortgage-Backed Securitizations Methodology” published in November 2021 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_1250766 and “Moody’s Approach to Rating Structured Finance Interest-Only (IO) Securities” published in February 2019 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_1111179. Please see the list of ratings at the top of this announcement to identify which classes are interest-only (indicated by the *). Alternatively, please see the Rating Methodologies page on www.moodys.com for a copy of these methodologies.DEAL PERFORMANCEAs of the November 15, 2021 distribution date, the transaction’s aggregate certificate balance has decreased by nearly 68% to $356 million from $1.1 billion at securitization. The certificates are collateralized by twelve remaining mortgage loans. Three loans, constituting 29% of the pool, have defeased and are secured by US government securities.Four loans, constituting 24% of the pool, are on the master servicer’s watchlist. The watchlist includes loans that meet certain portfolio review guidelines established as part of the CRE Finance Council (CREFC) monthly reporting package. As part of Moody’s ongoing monitoring of a transaction, the agency reviews the watchlist to assess which loans have material issues that could affect performance.Two have loans been liquidated from the pool, resulting in an aggregate realized loss of $13.7 million (for an average loss severity of 35%).The Shoppes at Buckland Hills loan ($108.5 million — 30.5% of the pool), is the one loan in special servicing. The loan is secured by a 535,000 square foot (SF) component of a 1.1 million SF regional mall located in the Buckland Hills section of Manchester, Connecticut, approximately 10 miles northeast of Hartford. The property’s anchors include traditional department stores Macy’s, Macy’s Men’s & Home, and JCPenney, as well as Dick’s Sporting Goods (only Dick’s Sporting Goods is included as part of the collateral). The property has one vacant anchor (141,000 SF) after Sears closed their location at the property in January 2021. Furthermore, Dick’s Sporting Goods (15% of the net rentable area (NRA)) announced it will be closing this location at their lease expiration in January 2022. The property’s trade area covers the northeastern suburbs of Hartford and parts of the north-central part of Connecticut and competes with several regional malls and power centers, including the Westfarms Mall, the dominant regional mall in the Hartford MSA. As of September 2020, the collateral component of the property was 94% leased, with an inline occupancy of 79%. The historical performance of the property generally trended down since securitization with the 2018 net operating income (NOI) approximately 14% lower than securitization levels. While increased revenue caused the property’s NOI to rebound to near underwritten levels in 2019, the property’s performance was significantly impacted by the pandemic and the year-end 2020 NOI DSCR was 0.92X, compared to 1.48X for year-end 2019. The property has also had exposure to several apparel tenants that have declared bankruptcy since 2019 or announced plans to reduce store counts. The loan transferred into special servicing in November 2020 due to delinquent payments after the borrower indicated they would no longer fund debt service and any operating shortfalls. Brookfield, the loan sponsor, agreed to a consensual receivership order, and a receiver has taken over management of the mall with the ultimate resolution to stabilize and sell the property. The loan has amortized approximately 16.5% since securitization and the loan is last paid through October 2021. As of the November 2021 remittance statement an appraisal reduction of 25% has been recognized on this loan since no updated appraisal has been reported.Moody’s has also assumed a high default probability for one poorly performing loan, Independence Hill Independent Living ($18.7 million — 5.3% of the pool), which is secured by a 294-unit multifamily garden apartment property located in San Antonio, Texas. The loan matures in March 2022 and the loan may face increased refinance risk as the property’s performance has deteriorated since 2018 from declining occupancy and the June 2021 NOI DSCR was 0.71X, down significantly from 1.46X in December 2019.Moody’s has estimated an aggregate loss of $76.4 million (a 60% expected loss) from the specially serviced and troubled loans.As of the November 2021 remittance statement cumulative interest shortfalls were $721,578. Moody’s anticipates interest shortfalls will continue because of the exposure to specially serviced loans. Interest shortfalls are caused by special servicing fees, including workout and liquidation fees, appraisal entitlement reductions (ASERs), loan modifications and extraordinary trust expenses.Moody’s received full year 2020 operating results for 100% of the pool, and partial year 2021 operating results for 87% of the pool (excluding specially serviced and defeased loans).The top three non-defeased performing loans represent 26.8% of the pool balance. The largest loan is the 9 MetroTech Center Loan ($48.9 million — 13.7% of the pool), which is secured by a leasehold interest in a nine-story, single-tenant office building located in the CBD of Brooklyn, New York. The property was built-to-suit for the New York City Fire Department (FDNY) in 1996 and serves as the department’s headquarters and the city emergency command center. In addition to approximately 317,000 SF of office space, the building also contains a two-story, below-grade, 137 space parking garage. The FDNY lease commenced in October 1997 and featured a 20-year term, with one, 10-year extension option exercisable. The FDNY exercised this option and extended their lease through October 2028. Due to the single tenant concentration, Moody’s value incorporates a lit/dark analysis due to the single tenant exposure. The loan has amortized 22% securitization and matures in February 2022. Moody’s LTV and stressed DSCR are 82% and 1.24X, respectively, compared to 85% and 1.20X at the last review.The second largest loan is the Midtown Square Shopping Center Loan ($29.4 million — 8.3% of the pool), which is secured by a 193,000 SF portion of a power center in Troy, Michigan. The property is shadow anchored by Target and Home Depot, and anchored by a Kroger grocery store. As of December 2020, the property was 98% leased. The loan has amortized nearly 16% since securitization and is scheduled to mature in February 2022. The loan had a June 2021 NOI DSCR of 1.87X and Moody’s LTV and stressed DSCR are 95% and 1.08X, respectively, compared to 87% and 1.17X at the last review.The third largest non-troubled loan is the University Park Shopping Center Loan ($17.0 million — 4.8% of the pool), which is secured by an 83,900 square foot retail property located in Denver, Colorado that was built in 2007. As of December 2020, the property was 93% occupied, compared to 96% in December 2019. The loan has amortized nearly 16% since securitization and is scheduled to mature in March 2022. The loan had a June 2021 NOI DSCR of 1.72X and Moody’s LTV and stressed DSCR are 86% and 1.31X, respectively, compared to 84% and 1.35X at the last review.REGULATORY DISCLOSURESFor further specification of Moody’s key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody’s Rating Symbols and Definitions can be found at: https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_79004.The analysis includes an assessment of collateral characteristics and performance to determine the expected collateral loss or a range of expected collateral losses or cash flows to the rated instruments. As a second step, Moody’s estimates expected collateral losses or cash flows using a quantitative tool that takes into account credit enhancement, loss allocation and other structural features, to derive the expected loss for each rated instrument.Moody’s did not use any stress scenario simulations in its analysis.For ratings issued on a program, series, category/class of debt or security this announcement provides certain regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series, category/class of debt, security or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody’s rating practices. For ratings issued on a support provider, this announcement provides certain regulatory disclosures in relation to the credit rating action on the support provider and in relation to each particular credit rating action for securities that derive their credit ratings from the support provider’s credit rating. For provisional ratings, this announcement provides certain regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on www.moodys.com.For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit rating action, the associated regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.The ratings have been disclosed to the rated entity or its designated agent(s) and issued with no amendment resulting from that disclosure.These ratings are solicited. Please refer to Moody’s Policy for Designating and Assigning Unsolicited Credit Ratings available on its website www.moodys.com.Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.Moody’s general principles for assessing environmental, social and governance (ESG) risks in our credit analysis can be found at http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1288235.At least one ESG consideration was material to the credit rating action(s) announced and described above.The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody’s affiliates outside the EU and is endorsed by Moody’s Deutschland GmbH, An der Welle 5, Frankfurt am Main 60322, Germany, in accordance with Art.4 paragraph 3 of the Regulation (EC) No 1060/2009 on Credit Rating Agencies. Further information on the EU endorsement status and on the Moody’s office that issued the credit rating is available on www.moodys.com.The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody’s affiliates outside the UK and is endorsed by Moody’s Investors Service Limited, One Canada Square, Canary Wharf, London E14 5FA under the law applicable to credit rating agencies in the UK. Further information on the UK endorsement status and on the Moody’s office that issued the credit rating is available on www.moodys.com.Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody’s legal entity that has issued the rating.Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosures for each credit rating. Rhett Terrell Analyst Structured Finance Group Moody’s Investors Service, Inc. 250 Greenwich Street New York, NY 10007 U.S.A. JOURNALISTS: 1 212 553 0376 Client Service: 1 212 553 1653 Matthew Halpern VP – Senior Credit Officer Structured Finance Group JOURNALISTS: 1 212 553 0376 Client Service: 1 212 553 1653 Releasing Office: Moody’s Investors Service, Inc. 250 Greenwich Street New York, NY 10007 U.S.A. JOURNALISTS: 1 212 553 0376 Client Service: 1 212 553 1653 © 2021 Moody’s Corporation, Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors and affiliates (collectively, “MOODY’S”). All rights reserved.CREDIT RATINGS ISSUED BY MOODY’S CREDIT RATINGS AFFILIATES ARE THEIR CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND INFORMATION PUBLISHED BY MOODY’S (COLLECTIVELY, “PUBLICATIONS”) MAY INCLUDE SUCH CURRENT OPINIONS. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT OR IMPAIRMENT. SEE APPLICABLE MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S CREDIT RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS, NON-CREDIT ASSESSMENTS (“ASSESSMENTS”), AND OTHER OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY’S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY’S ANALYTICS, INC. AND/OR ITS AFFILIATES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS, ASSESSMENTS AND OTHER OPINIONS AND PUBLISHES ITS PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE.MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY’S PRIOR WRITTEN CONSENT.MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.All information contained herein is obtained by MOODY’S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS” without warranty of any kind. MOODY’S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY’S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY’S is not an auditor and cannot in every instance independently verify or validate information received in the rating process or in preparing its Publications.To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY’S.To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING, ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY’S IN ANY FORM OR MANNER WHATSOEVER.Moody’s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody’s Corporation (“MCO”), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody’s Investors Service, Inc. have, prior to assignment of any credit rating, agreed to pay to Moody’s Investors Service, Inc. for credit ratings opinions and services rendered by it fees ranging from $1,000 to approximately $5,000,000. MCO and Moody’s Investors Service also maintain policies and procedures to address the independence of Moody’s Investors Service credit ratings and credit rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold credit ratings from Moody’s Investors Service and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at www.moodys.com under the heading “Investor Relations — Corporate Governance — Director and Shareholder Affiliation Policy.”Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided only to “wholesale clients” within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors.Additional terms for Japan only: Moody’s Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiary of Moody’s Group Japan G.K., which is wholly-owned by Moody’s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization (“NRSRO”). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any credit rating, agreed to pay to MJKK or MSFJ (as applicable) for credit ratings opinions and services rendered by it fees ranging from JPY125,000 to approximately JPY550,000,000.MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.