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       T R O U B L E D   C O M P A N Y   R E P O R T E R

                          E U R O P E

          Tuesday, August 6, 2019, Vol. 20, No. 156

                           Headlines



B U L G A R I A

FIRST INVESTMENT: Moody's Cuts LT Deposit Rating to B3


G R E E C E

INTRALOT S.A.: S&P Withdraws 'CCC+' Issuer Credit Rating


I R E L A N D

BLACK DIAMOND 2019-1: Moody's Rates EUR11MM Cl. F Notes B2(sf)
ORWELL PARK: Fitch Affirms BB+sf Rating on Class D Debt
RED1 FINANCE 2017-1: Moody's Affirms Ba2 Rating on Class F Debt
TAURUS 2016-1: Moody's Cuts EUR17.35MM Class F Notes Rating to Caa1


I T A L Y

BRIGNOLE CO 2019-1: Moody's Rates EUR3.2MM Class E Notes B3(sf)
DIOCLE SPA: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable


L U X E M B O U R G

INEOS GROUP: S&P Affirms 'BB' Corp. Rating, Outlook Stable


N E T H E R L A N D S

GLOBAL UNIVERSITY: Fitch Affirms 'B' LT Issuer Default Rating


T U R K E Y

GARANTI BBVA: S&P Alters Outlook to Negative & Affirms 'B+' ICR


U N I T E D   K I N G D O M

ASTON MARTIN: S&P Cuts Sr. Notes Rating to 'B-', Outlook Neg.
BURY FC: EFL Awaits Details on CVA, Future Remains Uncertain
HARLAND & WOLF: To Go Into Administration After Sale Efforts Fail
HAVELOCK INT'L: MP Talks with Administrators Following Collapse
IPAGOO: Enters Administration After FCA Halts Operations

PETRA DIAMONDS: Moody's Cuts CFR to B3; Alters Outlook to Stable
[*] UK: Scottish Corporate Insolvencies Up 45% in First Half 2019


X X X X X X X X

[*] EUROPE: Number of Distressed EMEA Cos. Rises in 1st Half 2019

                           - - - - -


===============
B U L G A R I A
===============

FIRST INVESTMENT: Moody's Cuts LT Deposit Rating to B3
------------------------------------------------------
Moody's Investors Service downgraded First Investment Bank AD's
long-term deposit ratings to B3 and changed the outlook to negative
from stable. Moody's also downgraded the bank's Baseline Credit
Assessment and Adjusted BCA to caa1 from b3, its long-term
Counterparty Risk Ratings to B1 from Ba3 and the Counterparty Risk
Assessment to Ba3(cr) from Ba2(cr). The short-term deposit rating
and CRR were affirmed at NP and the short-term CR Assessment at
NP(cr).

The rating action follows the publication of the results of a
comprehensive assessment of six Bulgarian banks by the European
Central Bank (ECB) on July 26, 2019, which included an asset
quality review (AQR) and stress tests based on December 31, 2018
carrying values, and reflects: (1) Moody's view that the quality of
FIBank's credit portfolio could pose a more significant risk to its
solvency than initially estimated, as highlighted by the
information provided by the AQR; and (2) the magnitude of the
capital shortfalls identified for FIBank, along with measures
already taken and expected to be taken by FIBank to address them.
The Bulgarian National Bank (BNB), which supervises FIBank, has
stated that it endorses the comprehensive assessment results, and
that, on the basis of the AQR results and post reference date
developments it estimates that each of the six banks included in
the exercise meet the own funds requirements of the European
Union's Capital Requirements Regulation.

The negative outlook reflects that any potential additional loans
classified as IFRS 9 stage 3 and stage 2, and resulting provisions,
could impact the bank's financial performance over next 12-18
months at a time when FIBank is working to improve the quality of
its loan portfolio, including through recoveries, foreclosures,
write-offs and sales of problematic exposures, and improve its
solvency buffers.

The full list of the affected ratings and assessments can be found
at the end of this press release

RATINGS RATIONALE

  -- RATING DOWNGRADE REFLECTS POTENTIAL HIGHER RISK IN THE BANK'S
CREDIT PORTFOLIO

The downgrade mainly reflects the potential higher credit risk in
FIBank's portfolio than previously estimated and therefore the
higher risk to solvency from problematic exposures. Namely, Moody's
considers that the AQR-adjusted nonperforming exposures (NPEs under
the expanded European Banking Authority definition), which are
significantly higher than those disclosed as of year-end 2018,
could pose potential material additional risk to the bank's
capital, as well as its profitability, than previously assumed.

The AQR, which is a prudential rather than an accounting exercise,
included 78% of the bank's entire credit portfolio and 95% of the
corporate portfolio and the AQR-adjusted NPE ratio for the bank's
overall credit exposures was 44.1%, compared to the unadjusted NPE
ratio of 19.1% as of year-end 2018. The additional NPEs were mainly
identified in the corporate portfolio, where the AQR-adjusted NPE
ratio was 56.2%, compared to 20.9% as of year-end 2018, and
resulted in an upward adjustment in provisions needed for this
portfolio.

Moody's already considered the risk to capital from a high level of
problem loans and a significant amount of repossessed assets
(mainly foreclosed properties) as the key driver for the FIBank's
standalone assessment. However, this assessment was previously
based on the last audited consolidated financials, whereby problem
loans (stage 3 loans under IFRS 9) to gross loans were 21.9% as of
end-2018 and coverage of problem loans (stage 3) by stage 3
provisions was modest at 44.5%. Higher problematic exposures, such
as those identified in the AQR, mandate additional provisions,
impacting profitability, and pose a further risk to capital in the
interim.

FIBank's BCA continues to reflect its relatively strong
preprovision earnings power and recovering bottom-line
profitability with a net income to tangible assets of 1.8% in 2018
from 1% in 2017 and its predominantly deposit-based funding
structure and sizeable liquidity buffers, which continue to be
counterbalanced by its evolving corporate governance practices and
the concentration of the bank's ownership that may give rise to key
man risk issues.

A secondary driver for the action are the capital shortfalls
identified in the comprehensive assessment exercise, also
considering actions already taken by FIBank and to be taken to
shore up capital buffers along with a supportive macroeconomic
environment in Bulgaria.

The AQR identified a capital shortfall of EUR125 million, mainly
from the previously mentioned AQR-estimated additional provisions
for corporate exposures. This exercise was complemented by
hypothetical baseline and adverse stress test scenarios for the
years 2019 to 2021. The capital shortfall for the baseline scenario
was EUR136 million and EUR263 million from the adverse. A common
equity tier 1 (CET1) capital ratio threshold of 8% threshold was
used for the AQR and the stress test's baseline scenario, and a
5.5% CET1 ratio threshold was used for the adverse scenario.
FIBank's 15.7% CET1 ratio as of the end of 2018 was used as a
starting point.

According to FIBank's own disclosures, the bank had already secured
EUR130 million in additional capital as of June 30, 2019, including
EUR65 million in preprovision income in the first half of 2019, and
that it plans to take measures to address the remaining EUR133
million through operating profit, de-risking of its corporate
portfolio and other measures.

  -- LOSS GIVEN FAILURE ANALYSIS DOES NOT RESULT IN ANY UPLIFT

Owing to the bank's relatively small proportion of loss-absorbing
junior depositors (the bank is predominantly funded by retail
deposits) and limited hybrid debt, the bank's deposit rating does
not benefit from rating uplift as a result of the application of
Moody's Loss Given Failure (LGF) analysis.

  -- MODERATE LIKELIHOOD OF GOVERNMENT SUPPORT

FIBank's B3 long-term deposit ratings continue to incorporate
Moody's assessment of a moderate likelihood of government support
in case of need for the bank, which results in one notch of rating
uplift. This support assumption is in line with the rating agency's
approach of assigning government support to European banks with
systemic importance despite the introduction of the Bank Recovery
and Resolution Directive (BRRD), which limits a government's
ability to support banks.

FIBank was the fourth-largest bank by assets and deposits in
Bulgaria as of the end of 2018. The reported market share of
deposits in Bulgaria was 9.6% as of end-2018. Furthermore, Moody's
support assessment is backed by the track record of support for
FIBank, which received liquidity support from the authorities in
2014.

  -- NEGATIVE OUTLOOK REFLECTS UNCERTAINTIES IN THE BANK'S
FINANCIAL PERFORMANCE

The negative outlook reflects that any additional IFRS stage 3 or
stage 2 loans recognised in the bank's accounts may require further
provisions and impact the bank's financial performance over the
next 12-18 months, including dampening net income and the pace of
the de-risking of the credit portfolio.

WHAT COULD CHANGE THE RATING UP/DOWN

Given the negative outlook on FIBank's deposit ratings, there is
currently limited upward rating pressure. The outlook could change
to stable, however, if FIBank is able to address the capital
shortfalls identified through private means, while significantly
reducing asset risk in its portfolio through a material decline in
problem loans and real estate assets, and significantly improved
provisioning coverage of problematic exposures.

A change in the bank's liability structure, such as through the
issuance of senior or subordinated and low-trigger hybrid debt,
could lead to changes in Moody's LGF analysis, resulting in an
uplift to the deposit ratings.

The bank's ratings could be downgraded if the bank does not address
the additional capital buffers identified within the coming
quarters and if its problem loans do not decline and the
provisioning coverage on problematic loans does not improve
materially during this period. A deterioration in the bank's
capital levels and profitability, or a decline in liquidity and
deposit outflows would also lead to a rating downgrade.

Changes in the bank's liability structure, mainly from an increased
reliance on secured funding, could result in a downgrade of the
deposit ratings. Finally, a lower likelihood or capacity of the
Bulgarian government to support FIBank, in case of need, may also
result in a downgrade of the deposit ratings.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Banks published
in August 2018.

FULL LIST OF ALL AFFECTED RATINGS

Issuer: First Investment Bank AD

Downgrades:

Adjusted Baseline Credit Assessment, Downgraded to caa1 from b3

Baseline Credit Assessment, Downgraded to caa1 from b3

Long-term Counterparty Risk Assessment, Downgraded to Ba3(cr) from
Ba2(cr)

Long-term Counterparty Risk Ratings, Downgraded to B1 from Ba3

Long-term Bank Deposits, Downgraded to B3 from B2, Outlook Changed
To Negative From Stable

Affirmations:

Short-term Counterparty Risk Assessment, Affirmed NP(cr)

Short-term Counterparty Risk Ratings, Affirmed NP

Short-term Bank Deposits, Affirmed NP

Outlook Action:

Outlook Changed To Negative From Stable



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G R E E C E
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INTRALOT S.A.: S&P Withdraws 'CCC+' Issuer Credit Rating
--------------------------------------------------------
On July 31, 2019, S&P Global Ratings withdrew its 'CCC+' issuer
credit rating on Greece-based gaming company Intralot S.A. and its
'CCC+' issue rating on the company's senior secured debt at the
company's request.

S&P said, "At the time of withdrawal, the rating had a negative
outlook, reflecting our view that the cash balances were likely to
continue to deplete in the next 6-12 months if the company proved
unable to dispose noncore assets and renegotiate its springing
covenants for its revolving credit facilities. The negative outlook
also reflected the likelihood that we would downgrade Intralot if
it appeared more likely to launch a distressed restructuring
transaction."




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I R E L A N D
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BLACK DIAMOND 2019-1: Moody's Rates EUR11MM Cl. F Notes B2(sf)
--------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to notes issued by Black Diamond CLO
2019-1 Designated Activity Company:

EUR3,000,000 Class X Senior Secured Floating Rate Notes due 2032,
Definitive Rating Assigned Aaa (sf)

EUR187,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032, Definitive Rating Assigned Aaa (sf)

USD34,360,000 Class A-2 Senior Secured Floating Rate Notes due
2032, Definitive Rating Assigned Aaa (sf)

USD25,000,000 Class A-3 Senior Secured Fixed Rate Notes due 2032,
Definitive Rating Assigned Aaa (sf)

EUR27,000,000 Class B-1 Senior Secured Floating Rate Notes due
2032, Definitive Rating Assigned Aa2 (sf)

EUR25,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2032,
Definitive Rating Assigned Aa2 (sf)

EUR22,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2032, Definitive Rating Assigned A2 (sf)

EUR25,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032, Definitive Rating Assigned Baa3 (sf)

EUR22,000,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032, Definitive Rating Assigned Ba3 (sf)

EUR11,000,000 Class F Senior Secured Deferrable Floating Rate Notes
due 2032, Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

The Issuer is a managed cash flow CLO. At least 90% of the
portfolio must consist of senior secured obligations and up to 10%
of the portfolio may consist of senior unsecured obligations,
second-lien loans, mezzanine obligations and high yield bonds. The
portfolio is expected to be 70% ramped up as of the closing date
and to comprise of predominantly corporate loans to obligors
domiciled in Western Europe. The remainder of the portfolio will be
acquired during the six month ramp-up period in compliance with the
portfolio guidelines.

Black Diamond CLO 2019-1 Adviser, L.L.C. will manage the CLO. It
will direct the selection, acquisition and disposition of
collateral on behalf of the Issuer and may engage in trading
activity, including discretionary trading, during the transaction's
four-year reinvestment period. Thereafter, subject to certain
restrictions, purchases are permitted using principal proceeds from
unscheduled principal payments and proceeds from sales of credit
risk obligations or credit improved obligation.

Interest and principal amortisation amounts due to the Class X
Notes are paid pro rata with payments to the Class A-1 Notes, Class
A-2 Notes and Class A-3 Notes. The Class X Notes amortise by 12.5%
or EUR 375,000 over the first eight payment dates starting on the
1st payment date.

In addition to the ten classes of notes rated by Moody's, the
Issuer will issue EUR 24,500,000 of Class M-1 Subordinated Notes
and USD 8,512,000 of Class M-2 Subordinated Notes which will not be
rated.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Methodology underlying the rating action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
March 2019.

Factors that would lead to an upgrade or downgrade of the ratings:

The rated notes' performance is subject to uncertainty. The notes'
performance is sensitive to the performance of the underlying
portfolio, which in turn depends on economic and credit conditions
that may change. The collateral manager's investment decisions and
management of the transaction will also affect the notes'
performance.

Moody's modeled the transaction using CDOEdge, a cash flow model
based on the Binomial Expansion Technique, as described in Section
2.3 of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

Moody's used the following base-case modeling assumptions:

Par Amount: EUR 400,000,000

Diversity Score: 54*

Weighted Average Rating Factor (WARF): 2900

Weighted Average Spread (WAS): 3.8%

Weighted Average Coupon (WAC): 6.0% for EUR assets /7.0% for USD
assets

Weighted Average Recovery Rate (WARR): 45.0%

Weighted Average Life (WAL): 8.5 years

* The covenanted base case diversity score is 55, however Moody's
has assumed a diversity score of 54 as the deal documentation
allows for the diversity score to be rounded up to the nearest
whole number whereas usual convention is to round down to the
nearest whole number.

Moody's has addressed the potential exposure to obligors domiciled
in countries with local currency ceiling (LCC) of A1 or below. As
per the portfolio constraints and eligibility criteria, exposures
to countries with LCC below Aa3 cannot exceed 10% and obligors
cannot be domiciled in countries with LCC below A3.

ORWELL PARK: Fitch Affirms BB+sf Rating on Class D Debt
-------------------------------------------------------
Fitch Ratings has upgraded Orwell Park CLO DAC's class A-2-R, B-R
and C-R notes and affirmed the rest. The transaction is a cash-flow
collateralised loan obligation backed by a portfolio of mainly
European leveraged loans and bonds.

Orwell Park CLO DAC
   
Class A-1-R XS1651871722; LT AAAsf Affirmed; previously at AAAsf

Class A-2-R XS1651871995; LT AA+sf Upgrade;  previously at AAsf

Class B-R XS1651872290;   LT A+sf Upgrade;   previously at Asf

Class C-R XS1651872456;   LT BBB+sf Upgrade; previously at BBBsf

Class D XS1229265670;     LT BB+sf Affirmed; previously at BB+sf

Class E XS1229265324;     LT Bsf Affirmed;   previously at Bsf


KEY RATING DRIVERS

End of Reinvestment Period

The upgrade reflects the end of the reinvestment period, a shorter
weighted average life (WAL) of the transaction and satisfactory
performance of the transaction. The transaction is passing all the
par value and coverage tests, collateral quality tests and
portfolio profile tests.

'B+/B' Portfolio Credit Quality

Fitch places the average credit quality of obligors in the 'B+/B'
range. The weighted average rating factor (WARF) of the current
portfolio is 31.72, below the current maximum WARF covenant of
34.5.

High Recovery Expectations

At least 90% of the portfolio comprises senior secured obligations.
Fitch views the recovery prospects for these assets as more
favourable than for second-lien, unsecured and mezzanine assets.
The Fitch-weighted average recovery rate of the current portfolio
is 66.25% above the minimum WARR covenant of 62.45%.

Portfolio Management

The reinvestment criteria allow the manager to reinvest proceeds
from prepayments and sale of credit-risk and -improved obligations
post reinvestment period, subject to satisfaction of the WAL test
and all other portfolio profile tests, and collateral quality tests
being maintained or improved, if failing.

Cash Flow Analysis

All liabilities are floating-rate while fixed-rate assets may
represent between 0% and 10% of the target par respectively. Fitch
tested both 0% and 10% fixed-rate assets and found the rated notes
can withstand the interest rate mismatch associated with each
scenario.

The calculation of the effective spread of assets having an
interest rate floor does not floor Euribor at zero and therefore
will lead to an inflated weighted average spread (WAS) due to a
negative Euribor. This overstatement of WAS is offset by a haircut
equal to the current 3-month Euribor applied on the maximum WAS
covenant of 3.7% modelled for the stressed portfolio.

RED1 FINANCE 2017-1: Moody's Affirms Ba2 Rating on Class F Debt
---------------------------------------------------------------
Moody's Investors Service upgraded four tranches of the credit
protection deed between Santander UK plc and Red1 Finance CLO
2017-1 DAC and affirmed two.

Moody's rating action is as follows:

GBP696.7M (Current Outstanding amount GBP 60.9M) Tranche A,
Affirmed Aaa (sf); previously on Dec 22, 2017 Assigned Aaa (sf)

GBP68.8M Tranche B, Upgraded to Aaa (sf); previously on Dec 22,
2017 Assigned Aa2 (sf)

GBP41.3M Tranche C, Upgraded to Aa3 (sf); previously on Dec 22,
2017 Assigned A2 (sf)

GBP22.9M Tranche D, Upgraded to A2 (sf); previously on Dec 22, 2017
Assigned Baa1 (sf)

GBP25.2M Tranche E, Upgraded to Baa2 (sf); previously on Dec 22,
2017 Assigned Baa3 (sf)

GBP22.9M Tranche F, Affirmed Ba2 (sf); previously on Dec 22, 2017
Assigned Ba2 (sf)

Moody's does not rate the Tranche G of the CPD.

RATINGS RATIONALE

The upgrade actions reflect the substantial increase in credit
enhancement for the senior tranches following the sequential
allocation of principal proceeds from loan repayments and the
stable or only moderately deteriorating loan performance. There are
three loans on the servicer's watchlist. The rating levels also
reflect stress scenarios due to the exposure to regional retail
properties and uncertainty in the UK commercial real estate market
around the outcome of Brexit.

Moody's rating action reflects a base expected loss in the range of
0%-5% of the current balance, which is the same as at the last
review. Moody's derives this loss expectation from the analysis of
the default probability of the securitised loans (both during the
term and at maturity) and its value assessment of the collateral.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was 'Moody's
Approach to Rating EMEA CMBS Transactions' published in November
2018.

Factors that would lead to an upgrade or downgrade of the ratings:

Main factors or circumstances that could lead to an upgrade of the
ratings are generally (i) an increase in the property values
backing the underlying loans, (ii) a decrease of the loans
monitored, (iii) an improvement in the loans' financial covenants.

Main factors or circumstances that could lead to a downgrade of the
ratings are generally (i) an increase in default risk assessment of
any of the loans backed by retail properties or (ii) a decline in
the property values backing the underlying loans.

MOODY'S PORTFOLIO ANALYSIS

As of the June 2019 IPD, the transaction balance has declined by
69% to GBP280.9 million from GBP916.8 million at closing due to the
pay-off of 15 loans originally in the reference pool. There are 10
UK commercial real estate loans remaining in the pool secured over
50 commercial and multi-family properties ranging in size from 1%
to 22% of the current pool balance. The Top 5 loans represent 79.2%
of the total portfolio amount compared to 26.6% at closing. The
pool has an above average concentration in terms of geographic
location (100% UK based on reported market value) and an average
concentration in terms of property type (53% office, 20% leisure,
20% retail and 7% industrial). Moody's uses a variation of the
Herfindahl Index, in which a higher number represents greater
diversity, to measure the diversity of loan size. Large
multi-borrower transactions typically have a Herf of less than 10
with an average of around 5. This pool has a Herf of 6.9,
significantly lower compared to 18.5 at closing.

Moody's weighted average LTV for the pool is 70% compared to a
reported 51%.

There are three loans on the servicer's watchlist, which are all
secured by retail properties including two loans due to refinance
in July and September 2019. The retail sector is experiencing
difficulties mainly driven by the ongoing shift to online sales and
changes in consumer behaviour as well as Brexit-related
uncertainties. 2019 is expected to be a difficult year for
retailers with further CVAs and administrations, and major
retailers announcing closures.

Brexit currently represents a high source of uncertainty for the UK
commercial real estate and in particular the London office sector.
Any deal which adversely impacts occupational demand from incumbent
or future tenants is likely to negatively impact both the rental
and investment markets. Red 1 Finance CLO 2017-1 DAC has exposure
to the sector (53% based on reported market value). However, the
loans benefit from a low LTV ranging from 37% to 66% and healthy
reported ICR levels.

TAURUS 2016-1: Moody's Cuts EUR17.35MM Class F Notes Rating to Caa1
-------------------------------------------------------------------
Moody's Investors Service downgraded the rating on one Class of
Notes and affirmed another five Classes of Notes issued by Taurus
2016-1 DEU DAC.

Moody's rating action is as follows:

EUR141.6M (Current Outstanding balance EUR 17.32M) Class A Notes,
Affirmed Aaa (sf); previously on Dec 4, 2017 Affirmed Aaa (sf)

EUR38.2M (Current Outstanding balance EUR 4.67M) Class B Notes,
Affirmed Aa1 (sf); previously on Dec 4, 2017 Upgraded to Aa1 (sf)

EUR25.5M (Current Outstanding balance EUR 3.12M) Class C Notes,
Affirmed A1 (sf); previously on Dec 4, 2017 Upgraded to A1 (sf)

EUR41.8M (Current Outstanding balance EUR 5.11M) Class D Notes,
Affirmed Baa1 (sf); previously on Dec 4, 2017 Upgraded to Baa1
(sf)

EUR52.6M (Current Outstanding balance EUR 6.43M) Class E Notes,
Affirmed Ba1 (sf); previously on Dec 4, 2017 Upgraded to Ba1 (sf)

EUR17.35M (Current Outstanding balance EUR 2.12M) Class F Notes,
Downgraded to Caa1 (sf); previously on Dec 4, 2017 Upgraded to B1
(sf)

RATINGS RATIONALE

The downgrade action on the Class F Notes is a result of deferred
interest amounts on the tranche. The issuer could not pay expenses
and full Note interest due to insufficient income from the
underlying loan following partial loan repayments due to property
sales combined with expenses not reducing proportionally. As at May
2019 IPD, the total unpaid interest on the Class F Notes is EUR
97,250.

Moody's expects this shortfall to continue increasing to 5-10% of
the Note balance. Furthermore, Moody's does not anticipate the
interest shortfall to be recovered given the loan is still
performing and paying all interest that is due on the loan. Any
principal proceeds from the loan are applied to the Notes on a
fully pro rata basis.

The transaction has deleveraged significantly since closing as a
result of property sales. There has been a total of 43 property
sales, which with a release premium of 115% on the majority of the
properties, has resulted in faster amortisation than initially
expected.

At the same time Moody's has affirmed the ratings on Classes A, B,
C, D and E Notes reflecting the improved performance of the
transaction due to property disposals and subsequent deleveraging
of the loan to a Moody's senior loan-to-value (LTV) ratio of 40.4%
from 82.5% at closing. Moody's has assessed the quality of the
remaining pool as similar to the initial pool and the current
rating levels reflect the decreased diversification of the
portfolio.

Moody's rating action reflects a base expected loss in the range of
0%-5% of the current balance, which is the same as at the last
review. Moody's derives this loss expectation from the analysis of
the default probability of the securitised loans (both during the
term and at maturity) and its value assessment of the collateral.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Approach to Rating EMEA CMBS Transactions" published in November
2018.

Factors that would lead to an upgrade or downgrade of the ratings:

Main factors or circumstances that could lead to an upgrade of the
ratings are generally (i) an increase in the property values
backing the underlying loan, (ii) sale of properties with a high
property release premium and subsequent loan repayments, (iii) a
decrease in default risk assessment.

Main factors or circumstances that could lead to a downgrade of the
ratings are generally (i) a decline in the property values backing
the underlying loan or (ii) an increase in default risk assessment,
(iii) higher than expected interest shortfalls or (iv) a
deterioration in the credit of the counterparties, especially the
interest rate cap provider, the liquidity facility provider and the
account bank.

MOODY'S PORTFOLIO ANALYSIS

As of the May 2019 IPD, the securitized balance has declined by 88%
to EUR 38.8 million from EUR 317.1 million at closing due to
prepayments from property disposals and scheduled amortisation. The
total senior loan balance has decreased to EUR 40.8 million from
EUR 333.7 million and the mezzanine loan balance to EUR 4.5 million
from EUR 37.3 million. All principal receipts paid on the Notes are
allocated pro-rata ensuring that credit enhancement levels remain
the same as at closing. As per the loan documentation, no further
scheduled amortization will be due when the UW LTV falls below
58.5% on the senior portion of the loan.

Since deal inception 43 properties have been sold, reducing the
portfolio to 12 from 55 properties at closing. The largest property
represents 21% of the current pool balance by allocated loan
amount. The pool has an above average concentration in terms of
geographic location (100% in Germany) and property type (100% in
retail & industrial/mixed use).

Moody's LTV on the senior loan has significantly decreased to 40.4%
from 82.5% at closing. The current Moody's LTV compares to the
current reported senior LTV of 31.9%. Moody's whole loan LTV is
44.9% as compared to the current reported whole LTV of 35.4%.



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I T A L Y
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BRIGNOLE CO 2019-1: Moody's Rates EUR3.2MM Class E Notes B3(sf)
---------------------------------------------------------------
Moody's Investors Service assigned the following definitive ratings
to ABS Notes issued by Brignole CO 2019-1 S.r.l.:

EUR278.1M Class A Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned Aa3 (sf)

EUR19.4M Class B Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned Baa2 (sf)

EUR14.6M Class C Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned Ba2 (sf)

EUR4.9M Class D Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned B2 (sf)

EUR3.2M Class E Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned B3 (sf)

EUR10.8M Class X Asset Backed Floating Rate Notes due July 2034,
Definitive Rating Assigned Caa2 (sf)

Moody's has not assigned any ratings to the EUR 3.2M Class F Asset
Backed Floating Rate Notes due July 2034.

RATINGS RATIONALE

The Notes are backed by a one-year revolving pool of Italian
unsecured consumer loans originated by Creditis Servizi Finanziari
SpA (unrated). This represents the first public securitisation
backed by consumer loans originated by this originator.

The portfolio of consumer loans extended to individuals resident in
Italy consists of approximately EUR 323.41 million as of July 2019
pool cut-off date. All loans pay fixed interest rates, are fully
amortising and must have paid a minimum of one scheduled instalment
prior to their sale to the portfolio.

The ratings are primarily based on the credit quality of the
portfolio, the structural features of the transaction and its legal
integrity.

According to Moody's, the transaction benefits from various credit
strengths such as: (i) the granular portfolio composition and good
geographical diversification; (ii) good historical performance data
with regards to defaults and arrears provided by the originator,
(iii) a non-amortising Cash Reserve equal to 2% of the aggregate of
Class A to Class E Notes balance which provides both liquidity and
principal loss coverage for Class A to Class E Notes and (iv) a
cash trapping mechanism from period 27. A sweep of collections
every two business days to the Issuer account partially mitigates
the commingling risk.

However, Moody's notes that the transaction features some credit
weaknesses such as: (i) a revolving period of 12 months, which
could lead to an asset quality drift; (ii) the weighted-average
portfolio yield floor of 6.90% during the revolving period, which
has been considered in the cash flow modelling of the transaction
and (iii) the fact that the servicer is unrated. Various mitigants
have been included in the transaction structure such as the back-up
servicer Zenith Service S.p.A. ("Zenith", unrated) that will step
in upon a servicer termination event, as well as a number of
performance triggers which will stop the revolving period if the
transaction performance worsens.

Interest Rate Risk Analysis: While all loans in the pool carry a
fixed interest rate, the rated notes carry a floating rate. To
partially mitigate this risk the Issuer has entered into a cap
agreement with Natixis (Aa3(cr)/P-1(cr)) with a strike of 1.50%,
i.e. the cap counterparty will pay to the Issuer any positive
difference between the Euribor on the Notes and 1.50%.

MAIN MODEL ASSUMPTIONS

Moody's determined the portfolio lifetime expected defaults of
4.0%, expected recoveries of 15.0% and Aa3 portfolio credit
enhancement of 16.0% related to borrower receivables. The expected
defaults and recoveries capture its expectations of performance
considering the current economic outlook, while the PCE captures
the loss Moody's expects the portfolio to suffer in the event of a
severe recession scenario. Expected defaults and PCE are parameters
used by Moody's to calibrate its lognormal portfolio loss
distribution curve and to associate a probability with each
potential future loss scenario in the ABSROM cash flow model to
rate consumer ABS transactions.

Portfolio expected defaults of 4.0% are lower than the Italian
Consumer Loan ABS average and are based on Moody's assessment of
the lifetime expectation for the pool taking into account: (i) the
historical performance of the loan book of the originator; (ii)
benchmarking with other similar transactions; and (iii) the fact
that the transaction is revolving for 12 months and the portfolio
concentration limits during that period.

Portfolio expected recoveries of 15.0% are in line with the Italian
Consumer Loan ABS average and are based on Moody's assessment of
the lifetime expectation for the pool taking into account: (i) the
historical performance of the loan book of the originator; (ii)
benchmarking with other similar transactions; and (iii) the
unsecured nature of the consumer loans in Italy.

PCE of 16.0% is lower than the Italian Consumer Loan ABS average
and is based on Moody's assessment of the pool which is mainly
driven by: (i) evaluation of the underlying portfolio, complemented
by the historical performance information as provided by the
originator; (ii) the relative ranking to originator peers in the
Italian Consumer loan market; and (iii) the one-year revolving
period. The PCE level of 16.0% at the country ceiling of Aa3
results in an implied coefficient of variation of around 60.0%.

The principal methodology used in these ratings was "Moody's
Approach to Rating Consumer Loan-Backed ABS" published in March
2019.

Factors that would lead to an upgrade or downgrade of the ratings:

Factors that would lead to a downgrade of the ratings include: (i)
increased counterparty risk leading to higher operational risk of
(a) servicing or cash management interruptions and (b) the risk of
increased cap counterparty linkage due to a downgrade of the cap
counterparty ratings; and (ii) economic conditions worse than
forecasted resulting in higher arrears and losses.

Factors that may cause an upgrade of the ratings of the notes
include significantly better than expected performance of the pool
together with an increase in credit enhancement of Notes.

DIOCLE SPA: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable
----------------------------------------------------------------
S&P Global Ratings assigned its 'B' issuer credit rating to Diocle
SpA, a pharmaceutical company that specializes in the sale and
marketing of generic drugs.

S&P's 'B' rating on Diocle SpA (DOC Generici) follows its recent
acquisition by ICG private equity group and Merieux Equity
Partners. After the transaction, they will own about 83% and 12%,
respectively, of the group, while management will retain the
remaining 5%.

The 'B' rating reflects DOC Generici's relatively modest scale of
operations, high geographic concentration in Italy, and potential
future regulatory framework risk, which constrains its business
profile. However, the rating benefits from the company's stable
market share in the oligopolistic Italian generics market, a
favorable regulatory framework that creates effective barriers to
entry and limits price competition, a track record of quick
time-to-market product launches, and increasing generics
penetration in Italy. With reported opening debt to EBITDA of 5.5x,
S&P believes DOC Generici's financial profile is highly leveraged.

Furthermore, the group's ownership by private-equity sponsor ICG
Group constrains our overall financial risk assessment. S&P said,
"That said, we expect the company to continually expand its EBITDA
base, which should translate into a gradual deleveraging over our
forecast horizon through 2020. We also expect the company to report
free operating cash flow (FOCF) within the EUR36 million-EUR39
million range in 2019-2020."

DOC Generici is based in Italy, where all the company's
commercialization and distribution efforts take place. The Italian
generics market is based on a reference reimbursed generic price
that is updated and published monthly by the AIFA, the Italian
healthcare regulator. This reference price is set at a 45%-75%
discount to the value of the originator for class A (reimbursable)
products. The National Health Service will reimburse only the
lowest priced generic in the reference price list. If there is a
mismatch between the reference price and any other product in the
market, the customer will have to pay the difference. However, and
for instance, if the price of the originator and the reference
price are the same, the customer will be fully reimbursed.

Because of this, the market is based on the price difference
between the reference and the originator price, making price
competition among generics players irrelevant. Furthermore, the
Italian regulator has banned free commercial discounts to
pharmacies and wholesale providers, replacing them with an 8%
additional maximum fixed margin. This effectively eliminates price
discount competition between pharmaceutical companies at the point
of sale, which reinforces the market positions of the existing
five-company oligopoly. In this group, DOC Generici secured 15.8%
market share as of December 2018.

S&P said, "We believe Doc Generici's relatively small operations
and lack of geographic diversification significantly constrain its
business risk profile. However, we note that the Italian regulatory
environment creates effective barriers to entry, as new entrants
cannot compete on prices or discounts to pharmacies. Furthermore,
DOC Generici benefits from underlying positive market dynamics
because generics penetration in Italy has increased. Class A
products reached a 28% penetration rate in 2018 due to increased
awareness and the supportive regulatory environment. We note that
generics penetration in Italy still lags other key European
countries, leaving significant headroom for growth.

"We consider the group's regulatory framework risk to be limited at
this stage. Under the current legislation, the Italian government
automatically generates savings of 45%-75% on products facing
patent expiry, which supports the budget. Moreover, the government
is unlikely to decrease reference prices because they are already
very low and further pressure could push generic companies out of
the market, leading to product shortages. That said, we do not rule
out future regulatory changes and we understand that any negative
change in the regulatory environment will have a material effect on
DOC Generici, which constrains our assessment.

"In our opinion, DOC Generici has good profitability, with adjusted
EBITDA margins of 36%-38%, owing to its solid and efficient supply
chain management. The company is involved in the marketing and
selling of pharmaceutical drugs, while it outsources all of its
manufacturing to other contract manufacturers. As a result, the
company has limited working capital needs and capital expenditure
(capex). This has allowed quick time-to-market product launches,
which is an important aspect of the Italian generic industry
because pharmacies tend to shortlist only three-to-four major
generics brands. First movers benefit from a higher market share in
relation to the new generic products, which is then difficult for
competitors to contest. We believe that failure to continue timely
new launches squeeze the company's market share and the rating.

"Despite having a well-balanced portfolio in molecules and
therapeutic areas, we consider the group reliant on favorable
patent cliff dynamics for organic growth. After three years of
substantial patent expiries, patent cliffs are expected to
moderate, which could lead to a smaller product pipeline and lower
growth. Having said that, we expect DOC Generici to benefit from
the ramp-up of its recently launched drugs, such as Olmesartan and
Cholecalciferol, and from the roll out of its ophthalmology and
cardiovascular franchises. We do not expect DOC Generici to engage
in cross-border activities or to enter the challenging biosimilar
market, due to its conservative business strategy.

"We consider DOC Generici's supplier base to be well managed and
based on long-standing relationships. The licensing contracts with
developers typically span five years and the majority include a
pass-through mechanism with a floor price, and no minimum set
volumes. However, we note that the company exhibits concentration
to Italian suppliers (46% of molecules), which further increases
its concentration risk to Italy.

"We believe DOC Generici's capital structure is highly leveraged as
a result of its debt-funded acquisition by private equity firm ICG
Group. We forecast adjusted debt to EBITDA of 5.5x-6.0x in 2019,
before decreasing to nearly 5.5x in 2020, thanks to the company's
EBITDA expansion. For the same period, we forecast FOCF of EUR36
million-EUR39 million per year, supported by low capex, and low
working capital requirements. Due to the group's asset-light
nature, capex represents only about 2% of sales and is mainly
related to the acquisition of dossiers of molecules to be launched
after patent expiration, and to support the launch of the new
ophthalmology and cardiovascular ventures.

"We understand that the group followed a deleveraging profile under
the ownership of its previous financial sponsors. Although we
expect it will now follow a similar path, any material increase in
debt as a result of acquisitions or dividend recapitalization could
put pressure on the rating. Overall, private-equity ownership of
the group and the uncertainty as to whether the new financial
sponsors will sustainably support DOC Generici's deleveraging
trajectory and FOCF generation weigh on our assessment."

The rating is in line with the preliminary rating S&P assigned on
June 10, 2019.

S&P said, "The outlook is stable because we expect DOC Generici to
generate continued EBITDA growth supported by the stability of the
Italian regulatory environment, ramp-up of recently introduced
products, launch of its ophthalmology and cardiovascular ventures,
and increasing generics penetration in Italy. This should allow the
company to sustain adjusted debt to EBITDA of 5.5x-6.0x in 2019 and
2020, while generating positive FOCF.

"We could lower the rating if DOC Generici's performance deviates
materially from our base case so that adjusted debt to EBITDA is
significantly above 6x or EBITDA interest coverage is below 3x for
a protracted period. We could also lower the rating if FOCF turned
negative due to higher-than-expected capex or working capital
outflows, or if the financial sponsor engaged in aggressive
dividend recapitalizations.

"We could raise the rating if we were convinced that the financial
sponsor would consistently support the group's deleveraging
trajectory such that adjusted debt to EBITDA could remain
comfortably within the 4x-5x range, supported by sustained FOCF
generation. We also could consider a positive rating action if the
company markedly increased the scale and diversity of its product
offerings, but we do not expect this in the near term."




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L U X E M B O U R G
===================

INEOS GROUP: S&P Affirms 'BB' Corp. Rating, Outlook Stable
----------------------------------------------------------
S&P Global Ratings affirmed its corporate rating on Ineos Group
Holdings S.A. at 'BB', its issue rating on its senior secured debt
at 'BB+', and its issue rating on its senior unsecured debt at
'B+'.

S&P affirmed its rating on Ineos Group Holdings (IGH) because
leverage across the wider Ineos group remains lower than at IGH
itself. That said, there is less headroom under IGH's stand-alone
assessment.

Market conditions across IGH's main olefin divisions are likely to
weaken further over the next few years. Additional olefins capacity
is due to come online in the U.S., which will put pressure on
margins in the region. As supply in the U.S. expands and trade
conditions between the U.S. and China remain uncertain, S&P sees a
risk that U.S. producers will increase sales to Europe, which could
depress margins in Europe.

The sector's cyclical decline has already affected IGH's
performance in the first half of 2019. During this period, Ineos
recorded EBITDA of only about EUR1 billion. S&P now forecasts
full-year EBITDA of about EUR2 billion, which is at the lower end
of our previous expectation of EUR2 billion–EUR2.3 billion.

As IGH's performance moderates in line with market trends, its
decisions regarding paying dividends and its investments will be
key to maintaining rating headroom. For example, IGH's leverage
rose after it upstreamed a substantial dividend of about EUR1.5
billion to its parent Ineos Ltd. in February 2019. S&P Global
Ratings-adjusted debt to EBITDA is about 3.6x for the second
quarter of 2019--previously, it anticipated that it would remain
below 3x through the cycle. S&P said, "If IGH continues to pursue
substantial investment projects or pays higher dividends than we
expect, to the detriment of its cash flow generation, the pressure
on its rating may intensify. That said, we still expect IGH to
comply with its internal financial policy target of below 3x
through the cycle (it was 2.8x at Q2 2019). We also expect adjusted
debt/EBITDA to remain below 4x, which we see as commensurate with
the current rating."

S&P said, "We expect IGH's capital expenditure (capex) to be about
EUR1.2 billion in 2019, about twice its historical level of about
EUR500 million-EUR600 million per year. Although IGH's substantial
investments limit its ability to reduce debt, they strengthen its
business position. IGH is investing in enhancing its chemical
intermediates capacity and improving its feedstock advantage in the
olefins business. Once these projects are live, we expect margins
to improve, even though in the short term such high capex puts
pressure on free operating cash flow.

"Despite the higher-than-expected leverage at IGH level, lower
leverage at the wider Ineos group still supports the current
rating. We view IGH as a core subsidiary of Ineos Ltd. because we
view IGH as highly unlikely to be sold and as having a strong
long-term commitment from senior management. The wider Ineos group
includes Ineos Styrolution, Inovyn, Ineos Enterprises, Ineos Oil &
Gas, and other smaller entities. We anticipate adjusted debt to
EBITDA at this wider group will be lower than that at IGH,
supporting the 'BB' rating.

"Our 'bb' group assessment still factors in our limited visibility
regarding the wider group's financial policy, mergers and
acquisitions (M&A), and planned capex. We emphasize capex, in
particular, because members of the wider group have announced that
they could engage in sizable projects such as shale gas fracking in
the U.K., expanding their oil and gas activities, and developing
and producing an off-road vehicle to succeed the Landrover
Defender.

"The stable outlook indicates that in the next six to 12 months,
higher leverage at Ineos Group Holdings will be balanced by the
relatively low indebtedness of other members of the wider Ineos
group. In our base case, we expect EBITDA of about EUR2 billion in
2019 and about EUR1.9 billion-EUR2.1 billion in 2020 as market
conditions moderate after reaching the top of the cycle in
2017-2018.

"We view IGH's adjusted debt to EBITDA of 2.0x-4.0x as commensurate
with the 'BB' rating. That said, our assessment of the credit
quality of the wider Ineos group--notably the leverage of other
Ineos entities, including Styrolution, Inovyn, Enterprises, and Oil
& Gas--is a crucial consideration."

Rating pressure could arise if leverage within the wider Ineos
group rose much higher than currently anticipated. This could occur
because:

-- Creditworthiness at the IGH level deteriorated. In this
scenario, S&P would observe one or more of the following: adjusted
debt/EBITDA exceeding 4.0x without expectation for near-term
recovery; persistently declining free operating cash flow; weaker
liquidity; or a change in financial policy (including large-scale,
debt-funded acquisitions or sizable dividends to shareholders).

-- Indebtedness at other Ineos entities rose higher than expected;
for example, if other Ineos entities saw their market environment
deteriorate beyond S&P's base case or if they engaged in
substantial debt-funded acquisitions. In this scenario, S&P could
lower the rating on IGH, even if adjusted debt to EBITDA at the IGH
level stayed below 4x.

In the next 12 months, S&P sees rating upside as limited. S&P may
raise the rating if the credit quality of the wider Ineos group
strengthened; for example, if leverage were lower than expected and
M&A and capex more predictable. At the IGH level, an upgrade would
depend on adjusted debt/EBITDA remaining at or below 2.0x over the
cycle.




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=====================

GLOBAL UNIVERSITY: Fitch Affirms 'B' LT Issuer Default Rating
-------------------------------------------------------------
Fitch Ratings has affirmed Global University Systems Holding B.V.'s
Long-Term Issuer Default Rating at 'B' with a Stable Outlook.
GUSH's senior secured rating has been downgraded to 'B+'/'RR3'/67%
from 'BB-'/'RR2'/72% and removed from Rating Watch Negative.

Markermeer Finance B.V.'s multi-tranche GBP-equivalent 800 million
senior secured term loan B and expanded GBP120 million revolving
credit facility, both guaranteed by GUSH, have also been downgraded
to 'B+'/'RR3'/67%.

This resolves the debt instruments' RWNs put in place since May
2019 when GUSH acquired a number of higher education service
companies and affiliated with two providers in India. The effect of
the acquisitions and finalised funding now in place has reduced its
recovery estimate on the senior secured debt to 67% - consistent
with 'RR3'.

KEY RATING DRIVERS

Acquisitive Entity: The May 2019 debt-funded acquisitions in India,
together with the prospective Caribbean R3 (medical) acquisition,
are consistent with GUSH's history of buying private
higher-education entities to complement group activities including
its central recruitment & retention division. Other existing group
entities include the University of Law (ULaw), online specialist
Arden University, University Canada West and St Patrick's
International College.

High FFO-based Leverage: Fitch expects GUSH to maintain funds from
operations (FFO)-adjusted net leverage at around 4x (similar levels
on an EBITDA basis), with post-acquisition spikes, and a FFO-based
fixed-charge cover ratio greater than 3x (fiscal year to November
30, 2018: 2.3x). Fitch expects FY19's FFO-adjusted gross leverage
to increase above its negative rating sensitivity of 6x but this
ratio only includes part-year EBITDA contributions from recent
acquisitions. Fitch projects this metric to return to 6x in FY20 on
a gross (4x net of cash) basis, in line with the rating (FY18: 5.7x
and 3.8x, respectively).

Recurring Diverse Income Stream: GUSH benefits from a varied income
stream stemming from its offering of geographically diverse,
single- or multi-year courses covering different subjects that also
span vocational and professional tuition. The group quotes high
student retention rates and successful employment rates. Revenue
visibility enhances management of the group's cost base. GUSH
continues to grow organic revenue using course material across
group entities, from growth of online education (through Arden),
and by targeting part-time as well as full-time offers.

Improving Cash Generation: Acquisitions may cause an increase in
leverage but GUSH has healthy prospective free cash flow (FCF)
which provides it with a capacity to deleverage within 18 to 24
months of a given size of acquisition.

Compared with its historical profile, GUSH has become more
cash-generative as (i) expensive debt was refinanced in January
2018; and (ii) the recruitment and retention division's
front-loaded multi-year revenue flows through to FFO for the group
in later years. In FY16 and FY17, these revenue flows did not
happen as this division's revenue included cash flows due to be
received in year two and three, whereas the cost base was expensed
as incurred. However, the difference between recognised EBITDA and
received cash narrowed in FY18 as those year-two and -three
receipts were collected and improved the group's FFO (FY18: GBP76
million).

Private Education Offer and Demand: GUSH's cash flow stability and
debt service capabilities are further supported by the non-cyclical
nature of higher education enrolment. There is growing inherent
demand for higher education both from within the UK and
particularly from emerging countries (Africa, Asia), coupled with
an attraction to study UK qualifications in London, online, or at
group entities overseas. The Indian and Caribbean/US acquisitions
further diversify GUSH's geographical presence.

Limited Impact from Brexit: Demand for GUSH's courses span local
and international students including emerging market countries
across Africa and Asia. With regard to Brexit, Fitch believes that
the UK government may raise the bar for overseas visa applications.
However, GUSH states that only 5% of its 2018 students were EU
students at UK institutions. Similar political noise concerning
oversea student visa applications in the US could affect the
group's volumes, although management reports little direct effect
at this stage.

DERIVATION SUMMARY

Compared with Fitch's credit opinions on private education
providers at the lower end of the 'B' rating category, GUSH
benefits from a more diversified income by geography and by type of
higher education (business, vocational/professional, under- and
post-graduate) as well as format (traditional campus or online
learning). Its ULaw and LSBF institutions have a higher profile
than some peers' portfolios. GUSH is able to plug its acquired
entities into the group's high-margin centralised recruitment and
retention platform, particularly since student recruitment and
marketing costs are a significant cost burden for smaller education
groups.

Compared with Dubai-concentrated and twice as large GEMS Menasa
(Cayman) Ltd (IDR: B(EXP)/Stable), GUSH has comparable FFO gross
leverage at around 6x. GUSH has a higher group EBITDA margin (LTM
May-2019: 35%) due to product mix, is more geographically diverse
and has a wider choice of courses and disciplines across physical
and digital course platforms. GUSH is more acquisitive than the
GEMS group of entities being financed, thus Fitch expects GUSH to
use its available FCF to acquire other entities to enhance its
recruitment & retention division platform. Fitch expects both
privately-owned groups to maintain their leverage at around 6x due
to debt funding of expansion plans.

KEY ASSUMPTIONS

  - Strong revenue growth over the next four years given
significant FY19 acquisitions (UPES, CAES and R3) and appetite for
future acquisitions. Fitch assumes GBP50 million of capital outlay
per year during FY20 to FY22.

  - Organic revenue growth to remain strong at around 6% to 8% per
year. This includes price increases, incremental revenue as courses
are developed for online, existing materials used across different
group entities, and capacity optimisation.

  -  Fitch's rating case keeps operating costs stable as a
percentage of revenue (without including the benefits of further
synergies), leading to the EBITDA margin remaining at around 32%.

  - A 20% tax rate.

  - Capex of around GBP30 million in FY19, increasing to GBP55
million in FY22. Free cash flow (FCF) to be used in FY20 and FY21
to acquire entities using GBP50 million cash each year at a
Fitch-assumed acquisition EBITDA multiple of 8x. Acquired entities
are assumed to have an EBITDA margin of 20%, resulting in
incremental revenue of around GBP31million.

KEY RECOVERY ASSUMPTIONS

New 'RR3' Recovery Estimate: Fitch believes GUSH is likely to be
sold or restructured as a going concern rather than be liquidated
in a distressed scenario given that the value of the business lies
in the strength of its institutions and recruiting operating
platform. Fitch-estimated going concern value amounts to GBP598
million.

Based on the 2018 Fitch-adjusted EBITDA of GBP104 million plus a
pro forma EBITDA for the R3 (Caribbean) and two Indian
acquisitions, group EBITDA is estimated at GBP138 million. Fitch
maintains an EBITDA discount of 20%, which translates into a
post-restructuring EBITDA of GBP111 million, a level at which the
group would be generating neutral-to-marginally positive FCF. This
discount is in line with peers', weighing up the stability of
GUSH's core European business schools, the risk profile of the
recruitment & retention division, and the visibility of revenue
(multi-year courses and new student enrolment numbers) a year
ahead. A multiple of 6x is in line with peers' and reflects the
business's portfolio diversification, healthy FCF potential and
strong brands.

After deducting 10% for administrative claims, its waterfall
analysis generated a ranked recovery in the 'RR3' band, indicating
a 'B+' for the senior secured ratings of the RCF and TLB, which
rank pari passu with each other and include an assumed fully-drawn
GBP120 million RCF. The waterfall analysis output percentage on
current metrics and assumptions was 67%. The decline in recovery
from 72% is due to the additional EUR230 million TLB added-on and
upsized GBP120 million RCF.



===========
T U R K E Y
===========

GARANTI BBVA: S&P Alters Outlook to Negative & Affirms 'B+' ICR
---------------------------------------------------------------
S&P Global Ratings said that it revised its outlooks on Garanti
BBVA (Garanti) and Garanti Finansal Kiralama A.S. (Garanti Leasing)
to negative from stable. At the same time, S&P affirmed the 'B+'
long-term issuer credit rating on Garanti and the 'B+/B' long- and
short-term issuer credit ratings on Garanti Leasing.

S&P believes that Garanti and Garanti Leasing are vulnerable to the
deteriorating operating conditions in Turkey.

Although at this stage Garanti remains an important element of
Spain-based parent Banco Bilbao Vizcaya Argentaria S.A. (BBVA)'s
long-term strategy, the uncertainty over the macroeconomic
conditions and the banking system in Turkey is leading us to
reassess the likelihood of extraordinary support that Garanti could
receive from BBVA. In this context, S&P noted that BBVA did not
provide any financial support to Garanti despite a material
worsening of the crisis in Turkey over the past year, and S&P
considers such support would be unlikely if the operating
environment in Turkey deteriorates further and turns into a severe
systemic crisis. This is in line with BBVA's approach to promoting
the financial independence of its subsidiaries and limiting
contagion risk within the group. It is also the result of BBVA's
multiple-point-of-entry resolution strategy.

S&P said, "In our opinion, all the remaining factors driving
Garanti's credit profile remain largely unchanged since our
previous review of the rating in April 2019. The 'B+' long-term
rating on Garanti reflects our view that the bank's financial and
business profiles are vulnerable to the deteriorating economic and
business environment in Turkey on the back of the depreciation of
the Turkish lira, worsening economic prospects, and higher
political risks. Under such conditions, we expect Garanti's lending
activity to moderate further--in line with that of other private
banks in Turkey. In addition, we believe that the projected
economic recession, alongside increasing unemployment, volatility
in the Turkish lira, and high interest rates, will likely
jeopardize borrowers' ability to meet their obligations. As such,
we anticipate that the bank's asset quality indicators will
deteriorate further over the next 12 months, with the share of its
nonperforming loans highly likely to reach around 7% of total loans
by the end of 2019, and its cost of risk remaining above 250 basis
points.

"Our rating on Garanti also factors in our anticipation of
declining organic capital generation based on rising credit losses
and greater pressure on margins. Finally, our rating factors in the
bank's heavier reliance on external debt than its foreign peers,
but similar to its domestic peers. This exposes Garanti to pricing
and rollover risks, since Turkish banks' capacity to access capital
markets at affordable prices has declined since mid-2018 amid
investors' growing concerns regarding the Turkish financial
system's creditworthiness.

"We equalized the ratings on Garanti Leasing with those on Garanti
because of Garanti Leasing's core status to Garanti.

The negative outlook on Garanti reflects the downside risks we see
for the bank's financial profile over the next 12 months, alongside
more limited parental support. The negative outlook on Garanti
Leasing mirrors that on Garanti.

"We could lower the rating on Garanti if further market turbulence
exacerbates the bank's already elevated refinancing
risks--significantly undermining its liquidity--and if, at the same
time, we see more intense pressure on the bank's asset quality and
solvency than we currently expect, pushing our risk-adjusted
capital ratio below 5%.

"We could revise the outlook to stable if we anticipate that
pressure on the bank's financial profile is abating, and if we
consider that its funding and liquidity positions are still
adequately balanced."




===========================
U N I T E D   K I N G D O M
===========================

ASTON MARTIN: S&P Cuts Sr. Notes Rating to 'B-', Outlook Neg.
-------------------------------------------------------------
S&P Global Ratings lowered its ratings on U.K.-based luxury sports
car manufacturer Aston Martin Lagonda (AML) to 'B-' from 'B'. The
outlook is negative.

S&P also lowered its issue ratings on AML's senior secured notes to
'B-' from 'B'.

S&P said, "The downgrade reflects our updated base case that AML
will exhibit lower volumes and revenues, pressured profitability,
and higher debt levels in fiscal 2019 and 2020 than we previously
expected. Although AML continued to grow sales in the Americas and
Asia Pacific in the first six months of 2019, the trend in the U.K.
and Europe has dropped sharply below expectations over the same
period.

"AML recently revised down its guidance for fiscal 2019 volumes,
and EBITDA and EBIT margins. Whereas our previous forecast for
revenue growth was more than 20% for fiscal 2019, we now expect low
single digit revenue growth. We adjust AML's reported EBITDA by
expensing the R&D that the company capitalizes and therefore our
revised forecast for a reported 20% EBITDA margin for fiscal 2019
translates into an S&P Global Ratings-adjusted EBITDA margin of
about 5% (previously we forecast this to be around 10%). This
equates to slightly less than half the absolute S&P Global
Ratings-adjusted EBITDA we previously expected AML to generate in
2019. With the inclusion of the $190 million mirror bond, we
anticipate gross debt to be about £856 million at end-FY2019. As a
result of both lower adjusted EBITDA and higher debt, we now
forecast our adjusted debt to EBITDA to rise to about 15x at
end-FY2019 (previously we expected 5x-6x for the year). FFO cash
interest cover, which we previously thought would rise toward 2.5x,
will now be around 0.9x. AML remains materially FOCF negative due
to ongoing high capital expenditure (capex) to support new model
development and roll-outs.

"We also note AML's weaker operating performance and credit metrics
are coinciding with the imminent launch of its new luxury SUV, the
DBX. The success of the DBX is critical to AML's ambitious growth
strategy and its creditworthiness. We note that the DBX's
timescales and milestones remain on track, with the global launch
slated for December 2019 and production starting in Q2 2020.

"We recognize the successful launches of the Aston Martin DB11, the
Aston Martin Vantage, and the DBS Superleggera, as well as other
special edition cars. AML continues to make good progress with its
ambitious plans to upgrade and refresh its entire range of luxury
sports cars, and expand into new segments (sport utility vehicles
[SUVs] and sedans) by 2022, which should improve profitability in
the coming years although such a strategy requires sustained high
R&D investment and capex. We therefore expect FOCF to remain
negative, with AML continuing to invest heavily in new model
development and launches through 2022." (After launching the DBX in
late 2019, AML plans to launch a mid-engine supercar in 2020 and an
ultra-luxury Lagonda-branded EV SUV in 2021). The company has
finished building a manufacturing plant at St Athan in Wales, which
should double its overall production capacity in the coming years
and support a new model roll out.

AML is exposed to rising geopolitical risks including those
associated with a potential no-deal Brexit and new U.S. tariffs.
AML exports a significant amount of the cars it produces in the
U.K. to the EU and the U.S. A no-deal Brexit could result in supply
chain shocks, tariffs on imports and exports, and a dip in consumer
confidence. Given that AML's production presence is concentrated in
the U.K., this could harm the company more than it would some of
its rated peers. S&P notes that AML's management is taking action
to hold additional inventory as a buffer and arrange for
alternative ports of entry and exit.

The possibility of new U.S. tariffs also presents a potential risk,
although the impact on AML would likely be less than that of a
no-deal Brexit. The U.S. government is currently weighing up
whether to impose tariffs on vehicles imported from Europe--a 25%
rate is on the table. Although AML could be negatively affected by
new tariffs, none of the six global luxury sports car manufacturers
(AML, Ferrari, Rolls-Royce, Lamborghini, Bentley, and McLaren) has
a production presence in the U.S. All these manufacturers would
therefore be subject to the same tariffs, and the competitive
landscape would not materially change. Tariffs would not give any
single manufacturer a significant pricing advantage over the
others. Luxury sports car customers also tend to be less price
sensitive than customers for mass-produced vehicles. S&P said, "We
anticipate that AML would be able to adjust pricing, in time, and
so pass some of the tariffs on. As such, we view U.S. tariffs as
less of a threat than a no-deal Brexit. At this stage, we view a
potential no-deal Brexit and new U.S. tariffs as event risks and we
do not include them in our base case."

The negative outlook indicates that in addition to
weaker-than-expected market volume growth and pressured
profitability, AML faces heightened event risk associated with a
potential no-deal Brexit and new tariffs on the vehicles that AML
exports to the U.S. S&P also notes that AML is about to launch its
new DBX luxury SUV, and that the success of this model is critical
to AML's ambitious growth strategy and ability to achieve positive
FOCF generation.

S&P said, "We could downgrade AML if FFO cash interest cover did
not improve to more than 1.5x over the next 12 months or if
liquidity sources to uses were to decrease to less than 1.2x. We
could also lower the ratings if the U.K. government were to press
ahead with a no-deal Brexit or if the U.S. government introduced
new vehicle import tariffs.

"We could revise the outlook to stable if AML were to sustain its
revised guidance of no further declines in volumes or profitability
for the next 12 months, while improving cash interest cover to more
than 1.5x, and maintaining at least adequate liquidity and an S&P
Global Ratings-adjusted debt to EBITDA ratio below 7x."

BURY FC: EFL Awaits Details on CVA, Future Remains Uncertain
------------------------------------------------------------
Simon Stone at BBC News reports that the future of Bury is on a
knife-edge, a source close to the effort to save the League One
club has told the BBC.

Bury had a second game of the season, at Accrington, called off on
Aug. 2, BBC relates.

According to BBC, the EFL said they still had not received enough
detail from owner Steve Dale about how he intended to fund a
Company Voluntary Arrangement (CVA) or the next two years' running
costs.

Bury are due to play an EFL Cup tie at Sheffield Wednesday, on Aug.
13, which is also in doubt, BBC states.

The source said a third postponement may have dire consequences,
BBC notes.

BBC Sport has been told the EFL have requested far greater detail
about Bury's funding plans than it was initially suggested would be
the case and, at this stage, it is unclear exactly how long it will
take to get the information needed, BBC discloses.

Bury remains under a transfer embargo and have, like Bolton, had 12
points deducted as a result of entering the CVA, which is classed
as an insolvency event, according to BBC.

Mr. Dale told BBC Radio Manchester on Aug. 3 that he will not
consider selling Bury until he has restored financial stability at
the club.


HARLAND & WOLF: To Go Into Administration After Sale Efforts Fail
-----------------------------------------------------------------
Ian Graham at Reuters reports that Harland and Wolff, the Belfast
shipyard that built the Titanic, will be put into administration
after its bankrupt Norwegian owner failed to find a buyer, as a
union supporting its workers called for the yard to be
renationalized.

The shipyard, whose towering yellow cranes dominate the Northern
Irish city's skyline, has been occupied by workers fearful for
their jobs since last week, relates.  According to Reuters, they
said on Aug. 5 they would block administrators from entering the
site.

"There has been a series of board meetings, the result of which is
that administrators will be appointed over the course of the day,"
Reuters quotes a Harland and Wolff spokesman as saying.

The business was put up for sale last year by Norwegian parent
Dolphin Drilling, which filed for bankruptcy in June, Reuters
recounts.



HAVELOCK INT'L: MP Talks with Administrators Following Collapse
---------------------------------------------------------------
Debbie Clarke at The Scotsman reports that Fife politicians have
described the collapse of Havelock International as "hugely
disappointing" and a "harsh blow" to local communities.

This was the reaction from Kirkcaldy MP Lesley Laird and Scottish
Liberal Democrat leader and North East Fife MSP Willie Rennie to
the news that the firm had gone into administration, The Scotsman
relates.

According to The Scotsman, Lesley Laird said it was crucial a buyer
is found to save the 247 jobs.

Ms. Laird, as cited by The Scotsman, said she had spoken to the
administrators and would be keeping in touch with them in the next
few days.

She said the key priority is to ensure the workers are paid for the
work they have already completed, The Scotsman notes.

Scottish Liberal Democrat leader and North East Fife MSP Willie
Rennie described the job losses as a "harsh blow" to Fife
communities, The Scotsman relays.

According to The Scotsman, he said: "The loss of this many jobs
will be a harsh blow to Kirkcaldy and the surrounding area.  For
workers who have given a lifetime's service this is the worst thing
that could happen.

"I hope that the Scottish Government will now work with unions and
the firm to ensure that knowledge and skills are not lost."

Meanwhile Scottish business minister Jamie Hepburn said the
immediate priority is the staff, The Scotsman recounts.


IPAGOO: Enters Administration After FCA Halts Operations
--------------------------------------------------------
Caroline Binham at The Financial Times reports that Ipagoo, which
offered online multicurrency accounts, has collapsed into
administration just days after the UK financial watchdog ordered it
to cease all regulated activity.

Customer accounts were frozen after the Financial Conduct Authority
intervened following concerns that Ipagoo had not properly
segregated customer money--a basic requirement for all regulated
financial firms, the FT relates.  The regulator forced it to secure
all its books and records, and file daily reports, the FT
discloses.

According to the FT, FRP Advisory has been appointed as
administrator to the payment-services firm and to its parent group
that developed the software Ipagoo used, Orwell Group Holdings.
FRP, as cited by the FT, said it was looking to transfer Ipagoo's
business to another regulated firm.

"In addition to the current restrictions over its activities,
Ipagoo has been suffering from a lack of working capital which left
the directors with no choice but to enter the business into
administration," the FT quotes Jason Baker, an FRP partner who is
one of the joint administrators, as saying.  "Our priority is now
to work closely with the regulators and the firm to complete the
required reconciliation exercise with a view to returning client
funds as soon as possible."

Ipagoo's most recent accounts show that it made a loss of GBP2.4
million in the year to March 2018, with financial support pledged
for the foreseeable future by Orwell Group, the FT states.  The
latter widened its operating losses to GBP9 million from GBP6.5
million over the same period, the FT notes.


PETRA DIAMONDS: Moody's Cuts CFR to B3; Alters Outlook to Stable
----------------------------------------------------------------
Moody's Investors Service downgraded Petra Diamonds Limited's
corporate family rating to B3 from B2 and its probability of
default rating to B3-PD from B2-PD. Moody's has also affirmed the
B3 rating on the $650 million senior secured notes due in May 2022
issued by Petra Diamonds US$ Treasury Plc, a wholly owned
subsidiary of Petra. The outlook on the ratings has been changed to
stable from negative.

RATINGS RATIONALE

The rating action reflects the challenging rough diamond price
environment that is weighing on Petra's financial performance and
creating uncertainty on the pace of deleveraging. Petra's
profitability, free cash flow generation and net debt position is
weaker than Moody's had expected for the B2 rating level, and in
particular net leverage is expected to have weakened in FY2019 from
the previous year. In Moody's view, a material improvement in the
operating environment over the near term is unlikely.

Moody's forecasts net debt/EBITDA of 3.7x and EBIT/interest expense
of 0.9x in fiscal year ended June 30, 2019 (FY2019). Given the
uncertainty in the recovery of high value stones, Moody's assumes
Petra's realized average diamond prices to be stable in the
near-term. The company is however exposed to a number of factors
outside its control, including fluctuations in diamond prices,
volatility in USD/ZAR exchange rate, and execution risks related to
mine operations.

Petra has made significant investments in recent years in order to
access new undiluted ore bodies at its Cullinan and Finsch mines.
While annual production volume is expected to remain stable at 3.8
million carats, deleveraging could be stronger than anticipated if
there is a higher recovery of exceptional stones. As an example,
Petra recovered two gem quality diamonds at Cullinan in H2 FY2019
which were sold for $20.4 million in total. This positively
impacted the H2 FY2019 average sales price of $120/carat at the
Cullinan mine and was meaningfully higher than the $96/carat
reported in H1 FY2019. The latter was the lowest reported average
sales price achieved since H1 FY2010.

The B3 rating factors in an increase of free cash flow generation
over the next couple of years with low levels of capex and no
dividend payment. Management is targeting $150-$200 million of free
cash flow over the next three years after taking into account $54
million in Black Economic Empowerment (BEE)-related debt payments.
Maintaining the B3 rating would require Petra to be on track to
reach these objectives in order to accumulate a cash balance
necessary to meaningfully reduce gross leverage.

Petra's liquidity is adequate, and as at June 30, 2019, the company
had cash balances of $89.5 million and ZAR1.5 billion ($106.6
million) in undrawn revolving credit facilities. This comprises of
a ZAR1 billion revolving credit facility that matures in October
2021 and a ZAR500 million working capital facility that is renewed
annually. In April 2019, the company successfully amended its bank
covenants, which still tighten semi-annually, and which under
Moody's forecasts leave little headroom for underperformance.
However, it is unlikely that Petra will have to use these
facilities.

Following the end of its capex cycle in FY2019, Moody's forecasts
free cash flow generation in excess of $65 million in FY2020.
Annual capex averaged $230 million over the FY2014-FY2018 period,
has fallen to about $85 million in FY2019 and Moody's expects it to
average $50-$60 million over the next three years. The company will
fully pay down the BEE debt by November 2021 after which the only
debt obligation will be the $650 million notes due in May 2022.

The current environment will challenge the company as it starts to
firm up its strategy for refinancing its May 2022 notes, but at the
same time the stable outlook reflects the near three years until
that maturity date, which allows some time for capex investments to
bear fruit, coupled with a growing cash balance and adequate
liquidity.

STRUCTURAL CONSIDERATIONS

Petra's $650 million senior secured second lien notes rank behind
the ZAR1.5 billion senior secured first lien revolving credit
facilities. These facilities are currently undrawn and are unlikely
to be used, considering the expected free cash flow generation over
the next several years. In addition, while the $54 million BEE
refinancing loan guarantee obligation is part of the first lien
creditor class, this debt will amortize over the next 2 years.
Moody's hastherefore now aligned the rating of the notes with the
CFR.

RATIONALE FOR STABLE OUTLOOK

The stable outlook balances the currently weak market conditions
while reflecting the expectation of positive free cash flow
generation going forward.

WHAT COULD CHANGE THE RATING UP/DOWN

The ratings could be upgraded if net leverage as measured by net
debt/EBITDA reduces towards 2.0x over the next two years and the
company appears to be able to execute the refinancing of the notes.
In addition, EBIT/interest expense would need to be sustainably
above 2.0x. An upgrade would also require an assessment of Petra's
medium to long-term investment and funding requirements to extend
the life of its mines.

The ratings could be downgraded if Petra does not follow a
deleveraging trajectory with net debt/EBITDA moving towards 2.5x by
FY2021. Failure to improve EBIT/interest expense well above 1.0x
could also create negative pressure. The ratings could also be
downgraded if rough diamond prices drop further or if there is a
deterioration in Petra's liquidity profile.

LIST OF AFFECTED RATINGS

Issuer: Petra Diamonds Limited

Downgrades:

Corporate Family Rating, downgraded to B3 from B2

Probability of Default Rating, downgraded to B3-PD from B2-PD

Outlook Action:

Outlook changed to Stable from Negative

Issuer: Petra Diamonds US$ Treasury Plc

Affirmation:

Backed Senior Secured Regular Bond/Debenture, affirmed B3

Outlook Action:

Outlook changed to Stable from Negative

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Mining
published in September 2018.

Petra is a rough diamond producer listed on the London Stock
Exchange, registered in Bermuda and with its group management
office domiciled in the United Kingdom. The company's core assets
are three underground mines in South Africa and one open pit mine
in Tanzania. For FY2019, Petra produced 3.9 million carats of
diamonds and reported $463.6 million in revenues.

[*] UK: Scottish Corporate Insolvencies Up 45% in First Half 2019
-----------------------------------------------------------------
Hannah Burley at The Scotsman reports that new figures suggest
Scottish insolvencies have risen by more than 45% this year amid
economic uncertainty and a volatile retail environment.

There were a total of 698 corporate insolvency
appointments--businesses entering into administration, receivership
or liquidation--in Scotland in the six months to June, representing
a jump from 479 in the first half of 2018, The Scotsman relays,
citing the latest analysis from KPMG.

The accountancy group recorded 661 cases involving a company
liquidation, while there were 37 administration and receivership
appointments, The Scotsman discloses.

Although KPMG acknowledged the political uncertainty surrounding
Brexit as creating "challenging conditions" for the business
community, it blamed the rise on wider economic volatility, with a
number of retailers among the most high-profile corporate
casualties in recent months, The Scotsman relates.

However, it said the results were "not all doom and gloom", with
the number of insolvencies in the three months to 30 June holding
steady compared with one year earlier, The Scotsman notes.  It
added that while there was a rise in the number of administrations,
which usually relate to large businesses, the figure remains
relatively low when compared to historic data, according to The
Scotsman.




===============
X X X X X X X X
===============

[*] EUROPE: Number of Distressed EMEA Cos. Rises in 1st Half 2019
-----------------------------------------------------------------
Oliver Telling at Bloomberg News, citing a report by Moody's
Investors Service, reports that the number of distressed companies
in Europe, the Middle East and Africa rose in the first half for
the first time in more than two years.

Moody's list of distressed companies rose to 47 from 39 in the
first half of the year, Bloomberg relays, citing the report
published on Aug. 1.

According to Bloomberg, Moody's senior analyst Kristin Yeatman said
the total count of EMEA businesses with a high probability of
default is also expected to expand in the next 12 months,
particularly in the event of a recession, as the number of
companies close to joining the list outnumbers those that could
leave it due to an upgrade.

Businesses are added to Moody's list of distressed companies when
they are downgraded to a rating at least six levels below
investment grade and have a "negative outlook", Bloomberg states.
They are removed from the list when they are upgraded, have their
ratings withdrawn, or default, Bloomberg notes.



                           *********


S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter-Europe is a daily newsletter co-
published by Bankruptcy Creditors' Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

Copyright 2019.  All rights reserved.  ISSN 1529-2754.

This material is copyrighted and any commercial use, resale or
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Information contained herein is obtained from sources believed to
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