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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, October 26, 2021, Vol. 22, No. 208

                           Headlines



C R O A T I A

DALEKOVOD: Competition Authority Okays Koncar Acquisition
ZAGREBACKI HOLDING: S&P Affirms 'B-' ICR, Outlook Negative


G E R M A N Y

REVOCAR 2021-2: Fitch Assigns Final BB Rating on Class D Notes
REVOCAR 2021-2: Moody's Assigns Ba1 Rating to EUR3.8MM Cl. D Notes


G R E E C E

NAVIOS MARITIME: Moody's Withdraws Caa1 CFR Amid Notes Redemption


I R E L A N D

ANCHORAGE CAPITAL: Fitch Affirms B- Rating on Class F Notes
AVOCA CLO XXV: Fitch Assigns 'B-(EXP)' Rating on Class F Debt
DILOSK RMBS 5: S&P Assigns B- Rating on X1-Dfrd Notes
DUNEDIN PARK: Fitch Assigns B-(EXP) Rating on Class F-R Notes
PALMER SQUARE 2020-2: Fitch Raises Class F Notes Rating to 'BB'

PENTA CLO 10: Fitch Assigns Final B-(EXP) Rating on Cl. F Debt
SOVCOMBANK PJSC: Fitch Withdraws 'BB+(EXP)' Rating


I T A L Y

SONDRIO: Fitch Corrects Sept. 1 Ratings Release
VERDE BIDCO: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable


L I T H U A N I A

MAXIMA GRUPE: S&P Alters Outlook to Stable & Affirms 'BB+' ICR


R U S S I A

ROSGOSSTRAKH PJSC: S&P Raises ICR to 'BB+', Outlook Stable
UZBEKNEFTEGAZ JSC: S&P Assigns 'BB-' ICR, Outlook Stable


T U R K E Y

TURKEY: S&P Affirms 'B+/B' Unsolicited Sovereign Credit Ratings


U N I T E D   K I N G D O M

ASDA: Taps Barclays to Raise GBP500MM Debt to Repay Bridge Loan
DERBY COUNTY FOOTBALL: Have Two "Very Serious, Credible Offers"
ELLIOT GROUP: Investors' Cash Used to Make Unsecured Loans
EUROSAIL PLC 2006-2BL: Fitch Affirms CCC Rating on Class F1c Debt
PROVIDENT FINANCIAL: Fitch Gives Final 'B+' Rating to Tier 2 Notes

RUBIX GROUP: S&P Puts 'B-' ICR on Watch Positive on Proposed IPO

                           - - - - -


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C R O A T I A
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DALEKOVOD: Competition Authority Okays Koncar Acquisition
---------------------------------------------------------
Annie Tsoneva at SeeNews reports that the intended joint
acquisition of Croatian power transmission equipment manufacturer
Dalekovod by Koncar Elektroindustrija and Malta's Construction Line
has received the green light from the competition authority of
North Macedonia where Dalekovod has a subsidiary, Dalekovod said on
Oct. 25.

According to SeeNews, the acquisition of sole control of Dalekovod
by Napredna Energetska Rjesenja, a newly-established joint venture
company of Croatian electrical equipment manufacturer Koncar
Elektroindustrija and Construction Line Limited, shall have no
impact in terms of significant prevention, limitation or distortion
of effective competition on the market, Dalekovod said in a filing
to the Zagreb bourse.

Croatian competition authority AZTN gave the green light to the
acquisition last month, SeeNews recounts.

On June 30, the shareholders of Dalekovod approved a proposal for
the company's financial restructuring made by Koncar and
Construction Line Ltd., SeeNews relates.  The proposal envisaged
cutting Dalekovod's share capital to HRK2.5 million
(US$386,000/EUR332,000) from HRK247.2 million to cover earlier
losses, only to further increase it to up to HRK412.5 million in
order to raise funding to cover the company's debt to creditors
under a pre-bankruptcy settlement agreement concluded in January
2014, SeeNews discloses.  As a result of the initial capital cut
approved by the Dalekovod's shareholders on June 30, the company
made a reverse stock split in July by consolidating every 100
shares into 1, and later the same month offered to potential
investors new ordinary shares at their face value of HRK10 each,
SeeNews states.

In late July, Koncar said its unit Napredna Energetska Rjesenja
will contribute 310 million kuna in cash to Dalekovod's capital
increase, SeeNews notes.  Founders of Zagreb-based Napredna
Energetska Rjesenja are Construction Line and Koncar's fully-owned
subsidiary Koncar Ulaganja.


ZAGREBACKI HOLDING: S&P Affirms 'B-' ICR, Outlook Negative
----------------------------------------------------------
S&P Global Ratings affirmed its 'B-' ratings on Zagrebacki
Holding.

The negative outlook indicates that S&P could lower the ratings if
it sees further liquidity pressure, managerial issues, or weaker
government support.

Recent management reshuffling, lack of a transparent strategy, and
talks of restructuring lead to uncertainties regarding Zagrebacki's
future. Since the appointment of the new city administration in May
2021, Zagrebacki's management board has changed twice. S&P said,
"We understand that the city aims to reorganize the company
starting with the merger of three affiliates into Zagrebacki during
2021, and is refinancing the company's short-term debt with
long-term loans ahead of the 2023 bond maturity to improve
liquidity and profitability. We understand that, although the new
strategy is underway, it needs to be finalized and approved by the
city's assembly, which will take time. We see the lack of
transparency on the company's strategy, with no stable management
board to execute it, as weighing on Zagrebacki's SACP."

Zagrebacki's weak liquidity continues to constrain the rating.
Zagrebacki's cash of Croatian kuna (HRK) 184 million (about EUR24.5
million) on Oct. 15, 2021, and projected operating cash flow of
about HRK310 million (EUR41.3 million) compare with HRK280
million-HRK300 million in loan amortization and lease payments
(EUR38 million), plus HRK350 million-HRK450 million in annual capex
over the next 12 months. In addition, Zagrebacki has a HRK89
million coupon on its local currency bond due in July 2022.
Meanwhile, the company's leverage remains very high, with funds
from operations (FFO) to debt projected at 3%-5% in 2021. S&P said,
"We expect the company's capital structure in 2021 to comprise
long-term loans (20%), short-term loans (20%), leases (13%), and
the local currency bond (47%). The company has HRK1 billion in
short-term revolving bank lines and is dependent on rolling it
over, which we view as a weakness. We still see a strong
relationship between Zagrebacki and domestic banks, and note that
the company has always managed to renew its short-term lines at a
good price. Nevertheless, recent news about motion for enforcements
related to HRK11 million and HRK14 million of accumulated trade
payables for two suppliers and the ongoing management reshuffle at
Zagrebacki emphasize refinancing risks. Therefore, we now assess
ZGH's SACP at 'ccc'."

S&P said, "At the moment, we continue to see a very high likelihood
that the city of Zagreb would support Zagrebacki Holding in the
event of distress, which currently underpins the 'B-' rating. We
see Zagrebacki as the government's vehicle to implement its
policies for the city of Zagreb. The company benefits from
long-term contractual relations with the city that protect its
near-monopoly position in providing essential public services and
infrastructure to the population of Zagreb. Zagrebacki's operations
range from gas distribution and supply, water treatment and supply,
waste collection and treatment, as well as city cemeteries,
pharmacies, markets, outdoor advertisement, and municipal housing.
We also believe that the city's full ownership of Zagrebacki and
its involvement in defining and establishing the company's
strategy, investment plan, and budget emphasize the very strong
link between Zagrebacki and the city. We therefore continue to
believe that, despite liquidity constraints at the city, in the
event of distress, the city would be willing and able to support
Zagrebacki in a timely manner. This is because a default of the
company would hurt the new city administration's reputation. That
said, we could change our view in the future if ongoing management
and strategic changes affect the city's ability to monitor
Zagrebacki's financial condition."

Outlook

S&P said, "The negative outlook reflects ZGH's weak liquidity, in
that refinancing in the next 12-18 months will depend on the city's
support and the company's ability to roll over its short-term debt.
We also expect significant changes to the group's structure and to
the city's policy to support the company once a stable management
board has been appointed; although the impact of such changes are
unknown. We forecast FFO to debt at only 3%-5% in 2021 but with no
material debt increases."

Downside scenario

S&P would lower its rating on Zagrebacki Holding if:

-- S&P sees signs of weakening government support;

-- The company can't roll over its short-term debt; or

-- The new strategy following the board's appointment has an
adverse impact on the company's liquidity

Upside scenario

S&P said, "We would revise the outlook to stable if we see a
significant improvement of Zagrebacki's liquidity, including no
deficit in a 12-month period, reduced reliance on short-term debt,
clear signs of unchanged city support, and a clear, sound strategy
at the company. Improving credit metrics on the back of stronger
operating performance would also be credit supportive. This is not
our base case for the next 12-18 months, however."




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G E R M A N Y
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REVOCAR 2021-2: Fitch Assigns Final BB Rating on Class D Notes
--------------------------------------------------------------
Fitch Ratings has assigned RevoCar 2021-2 UG's
(haftungsbeschraenkt) notes final ratings.

     DEBT              RATING
     ----              ------
RevoCar 2021-2

A XS2396099454    LT AAAsf  New Rating
B XS2396101706    LT Asf    New Rating
C XS2396108206    LT BBBsf  New Rating
D XS2396117025    LT BBsf   New Rating
E XS2396120086    LT NRsf   New Rating

TRANSACTION SUMMARY

This is the tenth public securitisation of German auto loan
receivables under the RevoCar brand. The receivables are granted to
private and commercial customers by Bank11 für Privatkunden und
Handel GmbH (Bank11) and may contain balloon portions. Additional
receivables will be purchased during a two-year revolving period.

Sufficient credit enhancement covers higher arrears and defaults
and larger losses projected after more severe assumptions were
applied and protects the ratings from the social and market
disruption caused by coronavirus and related containment measures.
Fitch views liquidity protection as sufficient to support the
current ratings. The sensitivity of the ratings to scenarios more
severe than currently expected is provided in Rating Sensitivity.

KEY RATING DRIVERS

Default Expectations Anticipate Recovery: Fitch has assigned a
default base case at 1.9%. It incorporates Fitch's expectation of a
continued economic recovery from the coronavirus pandemic and an
expected slight shift towards a larger 'balloon' loan share during
replenishment. The risks resulting from balloon payments and the
revolving period underpin Fitch's 6.25x default multiple at
'AAAsf'.

NPL Sales Improve Recovery Expectations: Recovery data provided for
RevoCar 2021-2 reflected proceeds from NPL sales, which were
excluded in previous data deliveries. Compared with RevoCar 2020,
the last Fitch-rated RevoCar transaction, Fitch assigned a 5pp
higher recovery base case at 45% and maintained the haircut at
50%.

Combined Waterfall/Strictly Sequential Amortisation: The
transaction benefits from a combined waterfall for interest and
principal receipts, which means that excess spread and principal
receipts are available to cover timely payment obligations (senior
fees and class A interest). The notes are amortised sequentially,
so all available funds are used to redeem the senior notes ahead of
junior notes.

Limited Pool Migration Potential: Fitch views the potential for
adverse portfolio migration as limited over the two-year revolving
period. The replenishment criteria are largely close to initial
pool attributes. Fitch views the performance triggers as adequate
to stop the revolving period in case of larger-than-expected losses
or insufficient excess spread.

Commingling Exposure Partially Mitigated: While all scheduled
payments are remitted to the issuer's accounts daily, prepayments
are transferred monthly. A reserve does not fully cover the risk of
commingling these collections. Fitch incorporated the potential
loss from commingled collections by deducting the exposed amount
(0.5% initial balance) from the receivables balance at closing.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Default rate increased by 10%:

-- Class A: 'AA+sf';

-- Class B: 'A-sf';

-- Class C: 'BBB-sf';

-- Class D: 'BB-sf'.

Default rate increased by 25%:

-- Class A: 'AA+sf';

-- Class B: 'BBB+sf';

-- Class C: 'BB+sf';

-- Class D: 'B+sf'.

Default rate increased by 50%:

-- Class A: 'AA-sf';

-- Class B: 'BBBsf';

-- Class C: 'BBsf';

-- Class D: 'Bsf'.

Recovery rate reduced by 10%:

-- Class A: 'AA+sf';

-- Class B: 'A-sf';

-- Class C: 'BBB-sf';

-- Class D: 'BB-sf'.

Recovery rate reduced by 25%:

-- Class A: 'AA+sf';

-- Class B: 'A-sf';

-- Class C: 'BBB-sf';

-- Class D: 'B+sf'.

Recovery rate reduced by 50%:

-- Class A: 'AA+sf';

-- Class B: 'BBB+sf';

-- Class C: 'BB+sf';

-- Class D: 'Bsf'.

Default rate increased by 10% and recovery rate reduced by 10%:

-- Class A: 'AA+sf';

-- Class B: 'A-sf';

-- Class C: 'BBB-sf';

-- Class D: 'B+sf'.

Default rate increased by 25% and recovery rate reduced by 25%:

-- Class A: 'AAsf';

-- Class B: 'BBBsf';

-- Class C: 'BBsf';

-- Class D: 'B-sf'.

Default rate increased by 50% and recovery rate reduced by 50%:

-- Class A: 'Asf';

-- Class B: 'BB+sf';

-- Class C: 'B+sf';

-- Class D: 'NRsf'.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Default rate reduced by 10%:

-- Class A: 'AAAsf';

-- Class B: 'A+sf';

-- Class C: 'BBB+sf';

-- Class D: 'BBsf'.

Default rate reduced by 25%:

-- Class A: 'AAAsf';

-- Class B: 'AA-sf';

-- Class C: 'A-sf';

-- Class D: 'BB+sf'.

Default rate reduced by 50%:

-- Class A: 'AAAsf';

-- Class B: 'AA+sf';

-- Class C: 'A+sf';

-- Class D: 'BBB+sf'.

Recovery rate increased by 10%:

-- Class A: 'AAAsf';

-- Class B: 'Asf';

-- Class C: 'BBBsf';

-- Class D: 'BBsf'.

Recovery rate increased by 25%:

-- Class A: 'AAAsf';

-- Class B: 'A+sf';

-- Class C: 'BBB+sf';

-- Class D: 'BB+sf'.

Recovery rate increased by 50%:

-- Class A: 'AAAsf';

-- Class B: 'A+sf';

-- Class C: 'A-sf';

-- Class D: 'BBB-sf'.

Default rate reduced by 10% and recovery rate increased by 10%:

-- Class A: 'AAAsf';

-- Class B: 'A+sf';

-- Class C: 'BBB+sf';

-- Class D: 'BB+sf'.

Default rate reduced by 25% and recovery rate increased by 25%:

-- Class A: 'AAAsf';

-- Class B: 'AAsf';

-- Class C: 'Asf';

-- Class D: 'BBBsf'.

Default rate reduced by 50% and recovery rate increased by 50%:

-- Class A: 'AAAsf';

-- Class B: 'AAAsf';

-- Class C: 'AA-sf';

-- Class D: 'Asf'.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch reviewed the results of a third-party assessment conducted on
the asset portfolio information, and concluded that there were no
findings that affected the rating analysis.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.

REVOCAR 2021-2: Moody's Assigns Ba1 Rating to EUR3.8MM Cl. D Notes
------------------------------------------------------------------
Moody's Investors Service has assigned the following definitive
ratings to Notes issued by RevoCar 2021-2 UG (haftungsbeschrankt):

EUR460.7M Class A Floating Rate Asset Backed Notes due September
2036, Assigned Aaa (sf)

EUR25.5M Class B Fixed Rate Asset Backed Notes due September 2036,
Assigned Aa3 (sf)

EUR7.5M Class C Fixed Rate Asset Backed Notes due September 2036,
Assigned Baa2 (sf)

EUR3.8M Class D Fixed Rate Asset Backed Notes due September 2036,
Assigned Ba1 (sf)

Moody's has not assigned ratings to the EUR2.5M Class E Fixed Rate
Asset Backed Notes due September 2036.

RATINGS RATIONALE

The Notes are backed by a 2-year revolving pool of German auto
loans originated by Bank11 fuer Privatkunden und Handel GmbH
("Bank11") (NR). This represents the tenth issuance out of the
RevoCar program.

The portfolio of assets amount to approximately 500 million as of
September 30, 2021 pool cut-off date. The Liquidity Reserve, for
senior fees and Class A Notes coupon payments (subject to servicer
related trigger events), will be funded to 0.5% of the total Notes
balance at closing and the total credit enhancement for the Class A
Notes will be 7.86%.

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 a (i) granular portfolio, (ii) an experienced
originator and servicer and (iii) a Swap structure is in place to
mitigate interest rate risk arising from fixed rate paying assets
and 1mEuribor-based Class A Notes provided by UniCredit Bank AG
(A1(cr)/P-1(cr)). However, Moody's notes that the transaction
features some credit weaknesses such as an unrated servicer or a
2-year long revolving period. Various mitigants have been included
in the transaction structure such as a back-up servicer facilitator
which is obliged to appoint a back-up servicer if certain triggers
are breached, as well as a performance trigger which will stop the
revolving period if the cumulative net loss ratio surpasses 0.3%
during the first year and 0.6% during the second year.

The portfolio of underlying assets was distributed through dealers
and to private individuals 97.1% and commercial borrowers 2.9%. To
finance the purchase of new 37.2% and used 62.8% cars. As of 30
September 2021 the portfolio consists of 31,381 auto finance
contracts with a weighted average seasoning of 6.2 months. The
contracts have equal instalments during the life of the contract
and a larger balloon payment at maturity. On average, the balloon
contracts account for 59.9% of the entire portfolio cash flows.

Moody's determined the portfolio lifetime expected defaults of
1.7%, expected recoveries of 30% and Aaa portfolio credit
enhancement ("PCE") of 9% related to borrower receivables. The
expected defaults and recoveries capture Moody's expectations of
performance considering the current economic outlook, while the PCE
captures the loss Moody's expect 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 cash flow model to rate Auto
ABS.

Portfolio expected defaults of 1.7% is in line with the EMEA Auto
ABS average and is based on Moody's assessment of the lifetime
expectation for the pool taking into account (i) historic
performance of the book of the originator, (ii) benchmark
transactions, and (iii) other qualitative considerations, such as
the high balloon component of the portfolio.

Portfolio expected recoveries of 30% is in line with the EMEA Auto
ABS average and is based on Moody's assessment of the lifetime
expectation for the pool taking into account (i) historic
performance of the originator's book, (ii) benchmark transactions,
and (iii) other qualitative considerations.

PCE of 9.0% is in line with the EMEA Auto ABS average and is based
on Moody's assessment of the pool which is mainly driven by: (i)
the relative ranking to originator peers in the EMEA market (ii)
the weighted average current loan-to-value of 88.2% which is in
line with the sector average and (iii) and 59.9% of the balloon
loans in the total pool. The PCE level of 9.0% results in an
implied coefficient of variation ("CoV") of 62.8%.

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
September 2021.

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

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.

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




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NAVIOS MARITIME: Moody's Withdraws Caa1 CFR Amid Notes Redemption
-----------------------------------------------------------------
Moody's Investors Service has withdrawn the corporate family rating
of Caa1 and probability of default rating of Caa2-PD of Navios
Maritime Acquisition Corporation (Navios Acquisition, company).
Prior to withdrawal, the rating outlook was under review for
upgrade.

RATINGS RATIONALE

The withdrawal reflects the successful conclusion of the merger
with Navios Maritime Partners L.P. (Navios Partners, B2 stable)
announced on October 15, 2021[1], and full redemption of Navios
Acquisition's ship mortgage notes as part of the process. As a
result, Navios Acquisition has become a subsidiary of Navios
Partners.

Navios Maritime Acquisition Corporation is an owner and operator of
tanker vessels.




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ANCHORAGE CAPITAL: Fitch Affirms B- Rating on Class F Notes
-----------------------------------------------------------
Fitch Ratings has assigned Anchorage Capital Europe CLO I DAC
refinancing notes final ratings. It has also removed the existing
class B, C, D-1, E and F notes from Under Criteria Observation
(UCO), and upgraded the class D-1 notes.

      DEBT                  RATING               PRIOR
      ----                  ------               -----
Anchorage Capital Europe CLO I DAC

A-1 XS1846660733      LT PIFsf   Paid In Full    AAAsf
A-1-R XS2398917133    LT AAAsf   New Rating
A-2 XS1846660907      LT PIFsf   Paid In Full    AAAsf
A-2-R XS2398917729    LT AAAsf   New Rating
B XS1846661111        LT AAsf    Affirmed        AAsf
C XS1846661384        LT Asf     Affirmed        Asf
D-1 XS1846661541      LT BBB+sf  Upgrade         BBBsf
D-2 XS1846661970      LT PIFsf   Paid In Full    BBBsf
D-2-R XS2399533798    LT BBB+sf  New Rating
E XS1846662432        LT BBsf    Affirmed        BBsf
F XS1846662358        LT B-sf    Affirmed        B-sf

TRANSACTION SUMMARY

Anchorage Capital Europe CLO I DAC is a cash flow collateralised
loan obligation (CLO) actively managed by the manager, Anchorage
Capital Group, LLC. The reinvestment period is scheduled to end in
July 2022. At closing of the refinance, the class A-1-R, A-2-R and
D-2-R notes were issued and the proceeds used to refinance the
existing notes. The class B, C, D-1, E, F and the subordinated
notes have not been refinanced.

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch-weighted average rating factor (WARF) of the current
portfolio is 26.2.

High Recovery Expectations (Positive): Over 98% 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 (WARR) of the portfolio is 63%

Diversified Portfolio (Positive): The top-10 obligors and
fixed-rate asset limits for this analysis are 20% and 15%,
respectively. The transaction also includes various concentration
limits, including the maximum exposure to the three-largest
Fitch-defined industries in the portfolio at 40%. These covenants
ensure that the asset portfolio will not be exposed to excessive
concentration.

Portfolio Management (Neutral): The transaction's reinvestment
period is scheduled to end in July 2022 and includes reinvestment
criteria similar to those of other European transactions. The
weighted average life covenant has been extended by 12 months to
6.3 years and the matrix was updated concurrently at closing.
Fitch's analysis is based on a stressed-case portfolio with the aim
of testing the robustness of the transaction's structure against
its covenants and portfolio guidelines.

Cash Flow Analysis (Neutral): The weighted-average life (WAL) used
for the transaction's stressed-case portfolio and matrices analysis
is three months less than the WAL covenant, to account for
structural and reinvestment conditions post-reinvestment period,
including passing the over-collateralisation and Fitch 'CCC'
limitation tests, among others. This ultimately reduces the maximum
possible risk horizon of the portfolio when combined with loan
pre-payment expectations.

Upgrade and Affirmations: The class B, C and E notes are at the
model-implied ratings (MIRs) based on the updated matrix. The class
F notes' 'B-sf' rating reflects a 'limited margin of safety', in
line with Fitch's definition of the rating, and under the actual
portfolio analysis also passes the rating default rate (RDR) at
'Bsf', ensuring a minimum cushion at the 'B-sf' rating. The class
D-1 notes have been upgraded by one notch, in line with the new
MIR. The class B, C, D-1, E and F notes have been removed from
UCO.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- An increase of the RDR at all rating levels by 25% of the mean
    RDR and a decrease of the recovery rate (RRR) by 25% at all
    rating levels will result in downgrades of no more than three
    notches, depending on the notes.

-- Downgrades may occur if the build-up of credit enhancement
    following amortisation does not compensate for a larger loss
    expectation than initially assumed due to unexpectedly high
    levels of defaults and portfolio deterioration.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A reduction of the RDR at all rating levels by 25% of the mean
    RDR and an increase in the RRR by 25% at all rating levels
    would result in upgrades of up to five notches depending on
    the notes, except for the class A notes, which are already at
    the highest rating on Fitch's scale and cannot be upgraded.

-- After the end of the reinvestment period, upgrades may occur
    on better-than-initially expected portfolio credit quality and
    deal performance, leading to higher credit enhancement and
    excess spread available to cover losses in the remaining
    portfolio.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset pool
and the transaction. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognised statistical rating organisations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


AVOCA CLO XXV: Fitch Assigns 'B-(EXP)' Rating on Class F Debt
-------------------------------------------------------------
Fitch Ratings has assigned Avoca CLO XXV DAC's expected ratings.

The assignment of final ratings is contingent on the final
documents conforming to information already received.

DEBT              RATING
----              ------
Avoca CLO XXV DAC

A      LT AAA(EXP)sf   Expected Rating
B-1    LT AA(EXP)sf    Expected Rating
B-2    LT AA(EXP)sf    Expected Rating
C      LT A(EXP)sf     Expected Rating
D      LT BBB-(EXP)sf  Expected Rating
E      LT BB-(EXP)sf   Expected Rating
F      LT B-(EXP)sf    Expected Rating

TRANSACTION SUMMARY

Avoca CLO XXV DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of corporate-rescue
loans, senior unsecured, mezzanine, second-lien loans and
high-yield bonds. Net proceeds from the notes issuance will be used
to fund a portfolio with a target par of EUR400 million. The
portfolio is actively managed by KKR Credit Advisors (Ireland)
Unlimited Company (KKR). The collateralised loan obligation (CLO)
has a 4.4-year reinvestment period and an 8.5-year weighted average
life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch weighted average rating factor (WARF) of the identified
portfolio is 26.13.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise 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 (WARR) of the identified portfolio is
62.73%.

Diversified Portfolio (Positive): The indicative maximum exposure
of the 10-largest obligors for assigning the expected ratings is
20% of the portfolio balance and fixed-rate obligations are limited
to 10% of the portfolio. The transaction also includes various
concentration limits, including the maximum exposure to the
three-largest Fitch-defined industries in the portfolio at 40%.
These covenants ensure that the asset portfolio will not be exposed
to excessive concentration.

Portfolio Management (Positive): The transaction has a 4.4-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed portfolio with the aim of testing the robustness of the
transaction structure against its covenants and portfolio
guidelines.

Cash Flow Modelling (Neutral): The WAL used for the transaction's
stressed portfolio and matrices analysis is 12 months less than the
WAL covenant, to account for structural and reinvestment conditions
in the post-reinvestment period, including passing the
over-collateralisation and the Fitch 'CCC' limitation tests, among
others. Combined with loan pre-payment expectations this ultimately
reduces the maximum possible risk horizon of the portfolio.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- An increase of the default rate (RDR) at all rating levels by
    25% of the mean RDR and a decrease of the recovery rate (RRR)
    by 25% at all rating levels will result in downgrades of no
    more than four notches, depending on the notes.

-- Downgrades may occur if the build-up of credit enhancement
    following amortisation does not compensate for a larger loss
    expectation than initially assumed due to unexpectedly high
    levels of defaults and portfolio deterioration.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A reduction of the RDR at all rating levels by 25% of the mean
    RDR and an increase in the RRR by 25% at all rating levels
    would result in an upgrade of up to five notches depending on
    the notes, except for the class A notes, which are already at
    the highest rating on Fitch's scale and cannot be upgraded.

-- After the end of the reinvestment period, upgrades may occur
    on better-than-initially expected portfolio credit quality and
    deal performance, leading to higher credit enhancement and
    excess spread available to cover losses in the remaining
    portfolio.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

The majority of the underlying assets or risk presenting entities
have ratings or credit opinions from Fitch and/or other Nationally
Recognized Statistical Rating Organizations and/or European
Securities and Markets Authority registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


DILOSK RMBS 5: S&P Assigns B- Rating on X1-Dfrd Notes
-----------------------------------------------------
S&P Global Ratings assigned its credit ratings to Dilosk RMBS No.5
DAC's class A, B-Dfrd, C-Dfrd, D-Dfrd, E-Dfrd, F-Dfrd, and X1-Dfrd
notes. At closing, the issuer will issue unrated class X2, Z1, and
Z2 notes.

The loans in the pool were originated by Dilosk DAC (Dilosk), a
nonbank specialist lender, under its ICS Mortgages brand over the
last two years.

While Dilosk was established in 2013, it has only been originating
BTL mortgages since 2017 and owner-occupied mortgages since late
2019, and thus historical performance data is limited.

The transaction includes up to 30% pre-funded amount where the
issuer can add loans up until the first interest payment date
subject to certain conditions.

Approximately 76.0% of the preliminary pool comprises
owner-occupied loans, and the remaining 24.0% are BTL loans.

The collateral comprises prime borrowers. All of the loans have
been originated recently and thus under the Irish Central Bank's
mortgage lending rules limiting leverage (through loan-to-value
limits) and debt burden (through loan-to-income limits).

No borrowers in the portfolio have a currently active payment
holiday as a result of the COVID-19 pandemic.

The transaction benefits from liquidity provided by a general
reserve fund, and in the case of the class A notes, class A
liquidity reserve fund.

Principal can be used to pay senior fees and interest on the notes
subject to various conditions.

The transaction incorporates a swap to hedge the mismatch between
the notes, which pay a coupon based on the three-month EURIBOR, and
certain loans, which pay fixed-rate interest before reversion.

At closing, the issuer will use the issuance proceeds to purchase
the beneficial interest in the mortgage loans from the seller. The
issuer grants security over all its assets in favor of the security
trustee.

There are no rating constraints in the transaction under S&P's
counterparty, operational risk, or structured finance sovereign
risk criteria.

  Ratings

  CLASS     RATING    CLASS SIZE    CLASS SIZE (%)
                      (MIL. EUR)
  A         AAA (sf)     280.4         83.5
  B-Dfrd    AA (sf)       27.7         8.25
  C-Dfrd    A+ (sf)       11.8         3.50
  D-Dfrd    BBB+ (sf)      7.6         2.25
  E-Dfrd    BB+ (sf)       5.0         1.50
  F-Dfrd    B- (sf)        2.5         0.75
  X1-Dfrd   B- (sf)        8.4         2.50
  X2        NR             4.2         1.25
  Z1        NR             0.8         0.25
  Z2        NR             4.2         1.25


DUNEDIN PARK: Fitch Assigns B-(EXP) Rating on Class F-R Notes
-------------------------------------------------------------
Fitch Ratings has assigned Dunedin Park CLO DAC 's refinancing
notes expected ratings.

The assignment of final ratings is contingent on the receipt of
final documents conforming to information already reviewed.

DEBT               RATING
----               ------
Dunedin Park CLO DAC

A-R      LT AAA(EXP)sf  Expected Rating
B-1-R    LT AA(EXP)sf   Expected Rating
B-2-R    LT AA(EXP)sf   Expected Rating
C-R      LT A(EXP)sf    Expected Rating
D-R      LT BBB(EXP)sf  Expected Rating
E-R      LT BB(EXP)sf   Expected Rating
F-R      LT B-(EXP)sf   Expected Rating
X-R      LT AAA(EXP)sf  Expected Rating

TRANSACTION SUMMARY

Dunedin Park CLO DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of corporate rescue
loans, senior unsecured, mezzanine, second-lien loans and
high-yield bonds. Net proceeds from the note issuance will be used
to redeem the outstanding rated notes. The portfolio is managed by
Blackstone Ireland Limited. The collateralised loan obligation
(CLO) envisages a 4.5-year reinvestment period and an 8.5-year
weighted average life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch-weighted average rating factor (WARF) of the identified
portfolio is 25.07.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise 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 (WARR) of the identified portfolio is 63.4%.

Diversified Portfolio (Positive): The indicative maximum exposure
of the 10-largest obligors for assigning the expected ratings is
18% of the portfolio balance and fixed-rate obligations are limited
to 10% of the portfolio balance. The transaction also includes
various concentration limits, including the maximum exposure to the
three-largest Fitch-defined industries in the portfolio at 40%.
These covenants ensure that the asset portfolio will not be exposed
to excessive concentration.

Portfolio Management (Positive): The transaction has a 4.5-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed-case portfolio with the aim of testing the robustness of
the transaction structure against its covenants and portfolio
guidelines.

Cash Flow Modelling (Neutral): The WAL used for the transaction's
stressed-case portfolio and matrices analysis is 12 months less
than the WAL covenant to account for structural and reinvestment
conditions post-reinvestment period, including passing the
over-collateralisation and Fitch 'CCC' limitation tests, among
others. Combined with loan pre-payment expectations, this
ultimately reduces the maximum possible risk horizon of the
portfolio.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- An increase of the default rate (RDR) at all rating levels by
    25% of the mean RDR and a decrease of the recovery rate (RRR)
    by 25% at all rating levels will result in downgrades of no
    more than four notches, depending on the notes.

-- Downgrades may occur if the build-up of credit enhancement
    following amortisation does not compensate for a larger loss
    expectation than initially assumed due to unexpectedly high
    levels of defaults and portfolio deterioration.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A reduction of the RDR at all rating levels by 25% of the mean
    RDR and an increase in the RRR by 25% at all rating levels
    would result in an upgrade of up to three notches depending on
    the notes, except for the class X and class A notes, which are
    already at the highest rating on Fitch's scale and cannot be
    upgraded.

-- After the end of the reinvestment period, upgrades may occur
    on better-than-initially expected portfolio credit quality and
    deal performance, leading to higher credit enhancement and
    excess spread available to cover losses in the remaining
    portfolio.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset pool
and the transaction. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognised statistical rating organisations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


PALMER SQUARE 2020-2: Fitch Raises Class F Notes Rating to 'BB'
---------------------------------------------------------------
Fitch Ratings has upgraded Palmer Square European Loan Funding
2020-2 DAC's class B, D, E and F notes, and affirmed the remainder.
All tranches except the class A notes have been removed from Under
Criteria Observation (UCO). The Outlook on the class C notes was
revised to Positive from Stable.

     DEBT              RATING            PRIOR
     ----              ------            -----
Palmer Square European CLO 2020-2 DAC

A XS2249894820    LT AAAsf   Affirmed    AAAsf
B XS2249895041    LT AAAsf   Upgrade     AA+sf
C XS2249895553    LT A+sf    Affirmed    A+sf
D XS2249895637    LT BBB+sf  Upgrade     BBB-sf
E XS2249895710    LT BB+sf   Upgrade     BBsf
F XS2249896106    LT BBsf    Upgrade     B+sf

TRANSACTION SUMMARY

Palmer Square European Loan Funding 2020-2 DAC is a static cash
flow CLO mostly comprising senior secured obligations, serviced by
Palmer Square Capital Management LLC.

KEY RATING DRIVERS

CLO Criteria Update: The upgrades reflect the impact of the
recently updated Fitch CLOs and Corporate CDOs Rating Criteria
(including, among others, a change in Fitch's underlying default
assumptions). The upgrade analysis was based on a Negative Outlook
scenario, which assumes a one-notch downgrade of the underlying
assets with a Negative Outlook.

Transaction Deleveraging: The upgrades also reflect the
amortisation of the class A notes by EUR53 million since closing in
December 2020, which has increased credit enhancements. Credit
enhancement for the class A, B, C, D, E and F notes has increased
to 41.6%, 30.4%, 22.4%, 14.5%, 10.4% and 8.6%, respectively. The
Positive Outlooks on the notes reflect the static nature of the
portfolio and expected further amortisation of the notes, if the
underlying assets continue to prepay and pay down.

Stable Asset Performance: The transaction's metrics have remained
broadly stable since closing. The transaction was marginally below
par by 0.003% as of the investor report in September 2021. The
transaction passed all coverage tests. As the transaction is
static, it does not have collateral quality tests or portfolio
profile tests. Exposure to assets with a Fitch-derived rating (FDR)
of 'CCC+' and below was 0%. The portfolio is also well-diversified
across various obligors and industries. The three-largest
industries comprise 29.03% of the portfolio balance, the top-10
obligors represent 15.48% of the portfolio balance and no single
obligor represents more than 1.65% of the portfolio.

'B+'/'B' Portfolio: Fitch assesses the average credit quality of
the transaction's underlying obligors in the 'B+'/'B' category. The
Fitch-calculated weighted-average rating factor (WARF) of the
portfolio is 22.28.

High Recovery Expectations: Senior secured obligations make up
99.21% of the portfolio. Fitch views the recovery prospects for
these assets as more favourable than for second-lien, unsecured and
mezzanine assets. The Fitch-calculated weighted average recovery
rate (WARR) of the portfolio is 68.71%.

Deviation from Model Implied Rating (MIR): For the class F notes,
the MIR is one notch above the assigned rating. The deviation
reflects that the MIR would not be resilient based on a scenario
that assumes a one-notch downgrade of assets with a Negative
Outlook. The deviation is motivated by the limited default-rate
cushion when considering this scenario in the analysis.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- An increase of the RDR (rating default rate) at all rating
    levels by 25% of the mean RDR and a decrease of the recovery
    rate (RRR) by 25% at all rating levels to the Outlook Negative
    scenario would result in downgrades of up to five notches,
    depending on the notes.

-- Downgrades may occur if the build-up of the notes' credit
    enhancement following amortization does not compensate for a
    larger loss expectation than initially assumed due to
    unexpected high level of default and portfolio deterioration.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A reduction of the RDR at all rating levels by 25% of the mean
    RDR and an increase in the RRR by 25% at all rating levels to
    the Outlook Negative scenario would result in an upgrade of up
    to five notches, depending on the notes.

-- Except for the class A and B notes, which are already at the
    highest 'AAAsf' rating, upgrades may occur if better-than-
    expected portfolio credit quality and deal performance and
    continued amortisation lead to higher credit enhancement and
    excess spread available to cover losses on the remaining
    portfolio.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset pool
and the transaction. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognised statistical rating organisations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


PENTA CLO 10: Fitch Assigns Final B-(EXP) Rating on Cl. F Debt
--------------------------------------------------------------
Fitch Ratings has assigned Penta CLO 10 DAC expected ratings.

The assignment of final ratings is contingent on the final
documents conforming to information already received.

DEBT                      RATING
----                      ------
Penta CLO 10 DAC

A               LT AAA(EXP)sf   Expected Rating
B-1             LT AA(EXP)sf    Expected Rating
B-2             LT AA(EXP)sf    Expected Rating
C               LT A(EXP)sf     Expected Rating
D               LT BBB-(EXP)sf  Expected Rating
E               LT BB-(EXP)sf   Expected Rating
F               LT B-(EXP)sf    Expected Rating
Subordinated    LT NR(EXP)sf    Expected Rating

TRANSACTION SUMMARY

Penta CLO 10 DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of senior unsecured,
mezzanine, second-lien loans and high-yield bonds. Note proceeds
will be used to fund a portfolio with a target par of EUR400
million. The portfolio is actively managed by Partners Group. The
collateralised loan obligation (CLO) has a five-year reinvestment
period and a nine-year weighted average life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch places the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch-weighted average rating factor (WARF) of the identified
portfolio is 24.93.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise 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 (WARR) of the identified portfolio is
64.61%.

Diversified Asset Portfolio (Positive): The transaction will have a
Fitch test matrix corresponding to a top-10 obligors' concentration
limit and a fixed-rate asset limit of 5%. The transaction also
includes various concentration limits, including the maximum
exposure to the three-largest Fitch-defined industries in the
portfolio at 40%. These covenants ensure that the asset portfolio
will not be exposed to excessive concentration.

Portfolio Management (Neutral): The transaction has a 5-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed-case portfolio with the aim of testing the robustness of
the transaction structure against its covenants and portfolio
guidelines.

Cash Flow Modelling (Neutral): Fitch's analysis is based on a
stressed-case portfolio with an eight-year WAL. The WAL used for
the transaction's stressed-case portfolio was 12 months less than
the WAL covenant to account for structural and reinvestment
conditions after the reinvestment period, including passing the
over-collateralisation and Fitch 'CCC' limitation tests.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- A 25% increase of the mean default rate (RDR) across all
    ratings and a 25% decrease of the recovery rate (RRR) across
    all ratings would result in downgrades of up to five notches
    across the structure.

-- Downgrades may occur if the build-up of the notes' credit
    enhancement following amortisation does not compensate for a
    larger loss expectation than initially assumed due to
    unexpectedly high levels of defaults and portfolio
    deterioration.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A 25% reduction of the mean RDR across all ratings and a 25%
    increase in the RRR across all ratings would result in
    upgrades of no more than three notches across the structure,
    apart from the class X and A-R notes, which are already at the
    highest level on Fitch's rating scale and cannot be upgraded.

-- After the end of the reinvestment period, upgrades may occur
    on better-than-expected portfolio credit quality and deal
    performance, leading to higher credit enhancement and excess
    spread available to cover losses in the remaining portfolio.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognised statistical rating organisations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


SOVCOMBANK PJSC: Fitch Withdraws 'BB+(EXP)' Rating
--------------------------------------------------
Fitch Ratings has withdrawn the expected 'BB+(EXP)' rating for PJSC
Sovcombank's (SCB) US dollar-denominated senior unsecured
Eurobonds.

Fitch is withdrawing the senior debt expected rating as it is no
longer expected to convert to a final rating. Fitch does not expect
this senior debt issue to proceed as previously envisaged. The
bonds were expected to be issued by SCB's Ireland-based SPV, Sovcom
Capital DAC, which was expected to on-lend the proceeds to SCB.

KEY RATING DRIVERS

Not applicable as the rating has been withdrawn

RATING SENSITIVITIES

Not applicable as the rating has been withdrawn

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Financial Institutions and
Covered Bond issuers have a best-case rating upgrade scenario
(defined as the 99th percentile of rating transitions, measured in
a positive direction) of three notches over a three-year rating
horizon; and a worst-case rating downgrade scenario (defined as the
99th percentile of rating transitions, measured in a negative
direction) of four notches over three years. The complete span of
best- and worst-case scenario credit ratings for all rating
categories ranges from 'AAA' to 'D'. Best- and worst-case scenario
credit ratings are based on historical performance.




=========
I T A L Y
=========

SONDRIO: Fitch Corrects Sept. 1 Ratings Release
-----------------------------------------------
Fitch Ratings corrects a commentary published on September 1, 2021
on Banca Popolare di Sondrio (Sondrio) to include Sondrio's EUR500
million, 1.25% senior preferred debt issuance, issued on July 13,
2021 and maturing on July 13, 2027 (ISIN XS2363719050).

The amended commentary is as follows:

Fitch Ratings has revised the Outlook on Banca Popolare di
Sondrio's (Sondrio) Long-Term Issuer Default Rating (IDR) to Stable
from Negative and affirmed the IDR at 'BB+' and Viability Rating
(VR) at 'bb+'.

The revision of the Outlook reflects Fitch's view that the
pandemic-related downside risks for the bank's asset quality and
profitability have eased. Sondrio's performance in 1H21 and Fitch's
medium-term expectations for its performance should provide some
headroom to absorb moderate deterioration of its profitability and
asset quality that may arise from the remaining pandemic-related
risks to the economic recovery in Italy.

KEY RATING DRIVERS

IDRS, VR AND SENIOR PREFERRED DEBT

Sondrio's ratings reflect its still weak asset quality and modest
profitability. However, Fitch expects that the bank's average risk
appetite and its credible impaired loan strategy should mitigate
asset quality pressure from the pandemic, and that profitability
should benefit from loan impairment charges (LICs) remaining under
control and strategic initiatives aimed at improving earnings
generation.

The ratings also reflect the bank's satisfactory regulatory
capitalisation and Fitch's expectation that it will maintain
capital ratios with ample buffers over requirements. Sondrio
benefits from adequate franchises in its regions of operations,
which results in a stable customer deposit base, underpinning a
sound funding and liquidity profile.

Sondrio's asset quality is a rating weakness, with an impaired loan
ratio of around 7% at end-June 2021, which is higher than the
domestic industry average of around 6% and weak compared with
international peers. The impaired loans reserve coverage ratio of
over 62% at end-June 2021 is adequate for the bank's credit risks.

Fitch expects Sondrio's impaired loan ratio to remain under
control, even in case of a weaker-than-expected economic recovery
in Italy, as the bank should be able to compensate possible asset
quality deterioration once the government support measures
gradually unwind through a combination of sales and effective
workout. Furthermore, the bank's contained amount of loan moratoria
at end-June 2021, at below 4% of gross performing loans, and
better-than-expected performance of loan moratoria with limited
default rates to date should mitigate near- to medium-term risks.

Sondrio's operating profitability is modest by international
standards and compared with stronger domestic rated banks, despite
good cost efficiency. Its operating profit/risk-weighted assets
(RWA) recovered to around 2.0% in 1H21 from 0.7% in 2020, due to
re-established business activities, increased core revenue and the
positive contribution of securities investments. In 1H21, LICs
decreased by over 40% yoy (including 1H20 losses from the doubtful
loans disposal). The benign impaired loan inflows and improving
macroeconomic scenario allowed for some releases of provisions in
1H21, which could continue in the coming quarters and sustain the
bank's profits.

The improved 1H21 performance suggests that the bank is in a
position to benefit from the economic recovery in Italy. Fitch
expects profitability to stabilise at around 1% of RWA in the
medium term, benefiting from higher business volumes if the economy
rebounds in line with Fitch's current expectations, continuing use
of the Targeted-Longer Term Refinancing Operations (TLTRO)
facilities to mitigate pressure on the interest margin, a strategy
aimed at expanding wealth management activities and ongoing cost
efficiency.

Sondrio's capitalisation is satisfactory, with a common equity Tier
1 (CET1) ratio of 16.7% at end-June 2021, sustained by acceptable
earning generation and historically prudent dividend payouts, which
allowed to maintain ample buffers over regulatory requirements.
Capital encumbrance by unreserved impaired loans improved to below
28% at end-June 2021 from its peak of 74% at end-2016, and Fitch
expects it to remain under control, in line with Fitch's
expectations on asset quality. However, capitalisation remains at
risk from large exposure to Italian government bond holdings at
about 240% of CET1 capital at end-June 2021.

The bank's funding and liquidity profile is sound. Customer
deposits are a stable source of funding, benefiting from the bank's
adequate franchise in its home regions and strong client
relationships. Funding sources are increasingly diversified through
the bank's access to both secured and unsecured wholesale funding
markets. Liquidity remains sound, thanks to adequate buffers of
unencumbered eligible assets and access to ECB financing.

Sondrio's 'B' Short-Term IDR is the only option mapping to a 'BB+'
Long-Term IDR.

Sondrio's long-term senior preferred notes are rated in line with
the bank's Long-Term IDR. Fitch expects the bank to use senior
preferred debt to meet its minimum requirement for own funds and
eligible liabilities. Fitch also does not expect the bank to build
up buffers of subordinated and senior non-preferred debt in excess
of 10% of RWA, which is required under Fitch's criteria to rate
senior preferred debt above the Long-Term IDR.

DEPOSIT RATINGS

Sondrio's 'BBB-' long-term deposit rating is one-notch above the
bank's Long-Term IDR to reflect protection from lower-ranking
senior preferred and Tier 2 debt buffer, as full depositor
preference is in force in Italy. The one-notch uplift also reflects
Fitch's expectation that the bank will maintain these buffers,
given the need to comply with minimum requirement for own funds and
eligible liabilities. The short-term deposit rating of 'F3' is in
line with Fitch's rating correspondence table for banks with 'BBB-'
long-term deposit ratings.

SUBORDINATED DEBT

Tier 2 debt is rated two notches below Sondrio's VR to reflect poor
recovery prospects. No notching is applied for incremental
non-performance risk because write-down of the notes will only
occur once the point of non-viability is reached and there is no
coupon flexibility before non-viability.

SUPPORT RATING AND SUPPORT RATING FLOOR

The Support Rating (SR) of '5' and Support Rating Floor (SRF) of
'No Floor' reflect Fitch's view that although external support is
possible, it cannot be relied upon. Senior creditors can no longer
expect to receive full extraordinary support from the sovereign in
the event that the bank becomes non-viable. The EU's Bank Recovery
and Resolution Directive and the Single Resolution Mechanism for
eurozone banks provide a framework for the resolution of banks that
requires senior creditors to participate in losses, if necessary,
instead of or ahead of a bank receiving sovereign support.

RATING SENSITIVITIES

IDRS, VR AND SENIOR PREFERRED DEBT

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- While rating upside is currently limited, a stronger and more
    stable operating environment combined with improved asset
    quality could be positive for the ratings. These factors would
    have to be accompanied by more diversified income sources,
    supporting sustained profitability enhancement.

-- Fitch would upgrade the long-term senior preferred debt by one
    notch if resolution buffers were to be met with senior non-
    preferred debt and more junior instruments or if the size of
    the combined buffer of junior and senior non-preferred debt is
    expected to exceed 10% of RWAs on a sustained basis.

Factor that could, individually or collectively, lead to negative
rating action/downgrade:

-- Sondrio's ratings remain sensitive to a significant weakening
    of the operating environment in Italy, which would result in a
    prolonged and substantial damage to the bank's asset quality
    and earnings causing significant capital erosion, including
    from higher-than-expected capital encumbrance from unreserved
    impaired loans. The bank's ratings could be downgraded if we
    expect its CET1 ratio to edge closer to 13% and its impaired
    loan ratio deteriorates to above 10%, especially if these
    result in capital encumbrance by impaired loans to increase
    close to or above 50%, without the prospect of recovery in the
    short term.

SR AND SRF

An upgrade of the SR and upward revision of the SRF would be
contingent on a positive change in the sovereign's propensity to
support the bank. In Fitch's view, this is highly unlikely,
although not impossible.

DEPOSIT RATINGS

The deposit ratings would likely be downgraded if the bank's
Long-Term IDR was downgraded. The deposit ratings are also
sensitive to a reduction in the size of the senior and junior debt
buffers to below 10% of RWAs.

SUBORDINATED DEBT

The subordinated debt rating is primarily sensitive to changes in
the VR, from which it is notched. The rating is also sensitive to a
change in the notes' notching, which could arise if Fitch changes
its assessment of their non-performance relative to the risk
captured in the VR.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Financial Institutions and
Covered Bond issuers have a best-case rating upgrade scenario
(defined as the 99th percentile of rating transitions, measured in
a positive direction) of three notches over a three-year rating
horizon; and a worst-case rating downgrade scenario (defined as the
99th percentile of rating transitions, measured in a negative
direction) of four notches over three years. The complete span of
best- and worst-case scenario credit ratings for all rating
categories ranges from 'AAA' to 'D'. Best- and worst-case scenario
credit ratings are based on historical performance.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.


VERDE BIDCO: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable
-----------------------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to Verde Bidco SpA (Itelyum) and its 'B' issue rating and '4'
recovery rating (average recovery prospects 30%-50%; rounded
estimate: 40%) to the senior secured notes.

The stable outlook reflects S&P's view that Itelyum's continued
organic growth and the successful expansion of its capacity to
treat waste will result in an adjusted EBITDA margin of about
16.8%-17.3% in 2022-2023 and robust funds from operations (FFO)
cash interest coverage above 2.5x.

Private equity firm Stirling Square Capital Partners (Stirling),
along with Deutsche Beteiligungs AG (minority investor), has
purchased Itelyum for its Fund IV from its Fund III for an
enterprise value of EUR785 million.

The acquisition was funded with EUR450 million of new senior
secured notes and a EUR312.5 million equity contribution.

Itelyum's dominant market shares in Italy and one-stop-shop service
offering are counterbalanced by its small scale and limited
geographical scope. S&P assesses positively the group's leadership
position in the Italian industrial hazardous waste processing and
recycling market with an estimated 6%-7% market share. It also has
89% market share in regeneration, and a 50% share in waste solvent
purification. In terms of competitive threats, the group has
front-loaded its investments and now has one of largest recycling
facilities in Europe, with two-to-three times the capacity of its
nearest Italian competitors and the capability to process 830
thousand tons of waste solvent per year. S&P said, "We believe this
protects it from the threat of new entrants. Further support comes
from the stringent regulatory framework in Italy, where it can take
three-to-four years for existing providers to receive approval to
increase authorized plant capacity, and where technical expertise
and track record are key to winning contracts. In addition, the
scope of the group's services and its ability to treat hazardous
waste throughout the whole lifecycle are key value propositions,
since we see the industrial hazardous waste treatment market as
relatively fragmented. At the same time, the group's competitive
position is constrained by what we see as its relatively small size
compared to other peers we rate in the environmental services
industry, with about EUR402 million in revenue and EUR85 million in
pro-forma company reported EBITDA for the 12 months ended June 30,
2021." However, it is larger than most of its direct competitors in
Italy. The group serves clients globally, but a significant portion
of its revenue -- about 80% -- is tied to the Italian market.

Itelyum operates in a sector that is characterized by an innate
resilience to external conditions, as evident from the group's
performance during the COVID-19 pandemic. S&P views the group's
business as resilient, although the pandemic and subsequent
lockdowns affected the performance of the regeneration segment. A
large reduction in volumes drove a 12.8% decrease in this segment's
revenue relative to the prior year. Nevertheless, the regeneration
segment still had resilient profitability through a treatment fee
from the National Consortium for the Management, Collection and
Treatment of Used Mineral Oils (CONOU), and an incentive mechanism.
The fee provides a floor on the profitability of this segment,
since it is inversely correlated with the market price of lubricant
oil. Performance in the two other segments, environment and
purification, was relatively strong despite the recession in Italy,
with low- to mid-single-digit revenue growth in 2020. This was
mainly due to outperformance in the pharmaceutical end market, to
which the purification segment is heavily exposed, and expanding
volumes in the environment segment, despite some declines in the
amount of waste treated from industries affected by the pandemic.

S&P said, "We believe that Itelyum is in a good position for growth
over 2022-2023 through the expansion of its service offering and
improvements in operational efficiency. Indeed, we expect future
organic growth and management initiatives to focus on increasing
processing capacity and enhancing the existing plant technology to
improve the output yield--the percentage of processed waste that is
regenerated during the treatment lifecycle. We believe that this
focus will represent the lion's share of Itelyum's capital program
and growth capital expenditure (capex), which we estimate will
increase to about EUR28 million-EUR30 million in 2021, before
declining toward historical levels of 3%-4% of sales in 2023." At
the same time, the group is seeking to improve profitability by
expanding its one-stop-shop offering, and making process
improvements, such as rationalizing its fleet of collection
vehicles and optimizing route density.

Itelyum operates in a sector that is set to benefit from new
regulation linked to increased awareness of sustainability and
adoption of circular-economy principles at the EU level. Itelyum's
business model is based on waste recycling and valorization
solutions, with the latter providing an economic- and
value-recovery service for polluted waste. S&P said, "We believe
that the group would benefit from growth in its capacity to treat
the increasing waste volumes diverted from landfills and
incinerators. For context, Itelyum's average plant utilization was
an estimated 66% in 2019, and will benefit from further investments
to increase the authorized capacity of existing plants. As such, we
believe that Itelyum is among the players that could benefit from
environmental directives promoting higher recycling targets within
the EU, since it has the capacity to process extra waste."

S&P said, "We understand that Itelyum is considering expansion into
industrial water treatment, which presents a large and fragmented
addressable market. We believe that Itelyum's foray into new
markets could occur through strategic acquisitions. This would also
offer Itelyum the possibility of entering new neighboring European
countries. That said, we view this expansion as a potential
medium-term objective that extends beyond our two-year forecast
horizon. As such, it is not part of our current base case for
2022-2023, and we do not forecast any mergers or acquisitions (M&A)
or cash outflows, except a deferred consideration of about EUR5.8
million as part of the acquisition of Italian water treatment and
purification company Castiglia in July 2021. We reflect this
deferred consideration in our range for Itelyum's free operating
cash flow (FOCF) of EUR8 million-EUR15 million in 2022-2023.

"We view Itelyum's leverage following the transaction as elevated
considering the size of its EBITDA base. The transaction saw the
issuance of EUR450 million in new senior secured notes, relative to
a statutory EBITDA base of EUR50 million in 2020, since we do not
include any EBITDA add-backs. Our base-case forecast is for
adjusted debt to EBITDA of 8.3x by year-end 2021, before gradually
reducing toward 7.0x-7.6x in 2022-2023. Our debt figure also
includes about EUR29 million of factoring liabilities, which we do
not expect to be repaid; and EUR6.3 million of post-retirement
obligations. Despite the high leverage, FFO cash interest coverage
remains resilient and strong, in our view, exceeding 2.5x in 2022
and 2023.

"The ratings are constrained by Itelyum's financial-sponsor
ownership. We assess as positive that the sponsor does not intend
to take any dividends and will likely remain invested in the
business for a longer period than the typical five-year lifecycle
for private equity. This is because Stirling first invested in
Itelyum in 2016 through its third fund. We also understand from our
conversations with the financial sponsor that any M&A funding would
likely come from equity contributions and internally generated cash
flow, which we would view as credit positive. That said, we assess
Itelyum's leverage as elevated. We reflect this by assigning an
'FS-6' score for the group's financial policy.

"The stable outlook reflects our view that Itelyum's continued
organic growth and the successful expansion of its capacity to
treat waste will result in an adjusted EBITDA margin of about
16.8%-17.3% and robust FFO cash interest coverage of above 2.5x in
2022-2023.

"We could lower the rating if Itelyum faces adverse operating
developments, with persistent and negative FOCF and the EBITDA
margin falling below 12%, without a high likelihood of improvement
over the next few years. We could also take a negative rating
action if the group fails to deleverage, or if it undertakes
significant debt-funded acquisitions, such that FFO cash interest
coverage falls below 2.0x.

"We see limited rating upside potential in the near term due to
Itelyum's relatively small scale and elevated leverage. However, we
could consider a positive rating action if the group significantly
increases in scale, in tandem with stronger EBITDA growth,
resulting in adjusted leverage falling to about 5.0x on a sustained
basis. In such a scenario, we would also expect to see the group
generate positive and material FOCF, alongside a commitment from
the financial sponsor to maintain leverage at about 5.0x."




=================
L I T H U A N I A
=================

MAXIMA GRUPE: S&P Alters Outlook to Stable & Affirms 'BB+' ICR
--------------------------------------------------------------
S&P Global Ratings revised its outlook on Maxima Grupe UAB (Maxima)
to stable from negative and affirmed its 'BB+' long-term issuer
credit and issue ratings on the group and its senior unsecured
debt.

The stable outlook reflects Maxima's earnings growth, resulting in
debt to EBITDA of about 2.6x-2.9x for Maxima and 2.0x-2.5x for the
wider VP group in 2021 and 2022, with timely bond refinancing
expected early next year and dividends not exceeding free operating
cash (FOCF) after lease payments.

Maxima's operating performance in 2020 and 2021 exceeded our
expectations and S&P now forecast stronger credit metrics.

Maxima's trading performance was mainly supported by its store
expansion, with 101 new stores in 2020, and stronger food demand in
its developed e-commerce channel Barbora, which represented about
3.4% of revenue in the Baltics. However, like-for-like sales were
modest due to intensifying competition in the Baltics. Cost
efficiencies and optimized promotional activities realized during
the pandemic resulted in adjusted EBITDA margins improving 90 basis
points (bps) in 2020. S&Ps aid, "We expect this trend to hold in
2021, underpinned by about 100 new stores, moderate positive
like-for-like growth across geographies, and a robust EBITDA
margin, which remains somewhat above prepandemic levels despite
moderating from second-half 2021. Consequently, Maxima achieved
lower adjusted leverage of 2.8x in 2020, compared with the
2.9x-3.1x that we expected previously. In light of resilient
trading and cash generation, we expect these stronger credit
metrics to persist in 2021."

Maxima's switch in focus to Poland from more saturated Baltic
markets supports diversification and reduces the impact of
competition from large food retailers. Maxima has a market leading
position in the Baltic region and superior profitability in
Lithuania. S&P said, "However, we see the risk that this could
deteriorate following the entry and expansion of Lidl, a leading
international player focused on competitive pricing, in the Baltic
region. We also forecast slower growth in increasingly saturated
Baltic markets. That said, we acknowledge Lidl is a discount
retailer, which leaves room for the premium, quality, and fresh
assortments that Maxima is more associated with in the Baltics."
The group's well diversified store formats also enable it to
capture a large customer base and strengthen its competitive
advantage. Maxima is focusing on expansion outside the Baltics in
Poland, following the acquisition of local food retail chain
Emperia in 2018, and ramping up its small business in Bulgaria.
Given Poland's overall market size and Maxima's brand awareness
there, S&P sees high growth potential, with most of the about 100
store openings planned in the country. In 2020, the Polish business
saw revenue growth of about 10% and company adjusted EBITDA growth
of about 30%, which indicates much better growth prospects despite
Maxima's limited market share, and it has demonstrated solid
execution of the expansion so far.

Deleveraging remains constrained by higher-than-usual capital
expenditure (capex) and continued dividend distributions. S&P
expects Maxima to add about 100 new stores annually in the next two
years, leading to higher capex. It also pays sizeable dividends to
parent company VP. In 2021, it paid EUR106 million and we expect
about EUR80 million-EUR90 million annually in 2022 and 2023. This
financial policy will consume most of the strong operating cash
flows expected for the next two years from growth and Maxima's high
profit levels. Following exceptionally high discretionary cash flow
(DCF) after lease payments, capex, and dividends of about EUR50
million in 2021, S&P also expects only neutral DCF. This limits
cash accumulation and any material debt reduction in absolute
terms.

Maxima's financial policy supports the current rating but limits
upside. S&P said, "Due to sizable discretionary spending on
dividends and planned investments, we see Maxima's credit metrics
at the weaker end for the current rating level over the next two
years. We take comfort from its resilient adjusted FOCF to debt of
15%-20% in 2022 and 2023, which demonstrates high cash generation
and a robust ability to withstand potentially stronger than
expected operating setbacks. This is coupled with our view of a
supportive financial policy framework and the management and
shareholder commitment to maintain leverage broadly within our
expectation for the rating. At the same time, we understand that
management intends to maintain an efficient balance sheet at
Maxima, with no real deleveraging below currently anticipated
levels on a sustainable basis."

S&P said, "The VP group continues to support our rating on Maxima.
Maxima is part of VP, a wider group that includes geographically
diversified pharmacy business Euroapotheca UAB, real estate
business Akropolis Group UAB, as well as ERMI Group UAB, which has
retail operations in construction, finishing materials, and
household products in Lithuania and Estonia. These entities were
positive contributors to the group's overall profitability and cash
flow in 2020 and provide diversity in industries beyond food
retail. Since Maxima still represents nearly 75% of VP group, its
stronger than expected performance has positively affected overall
results. In addition, we highlight that shareholder distributions
at the VP level are lower compared to Maxima and cash generation is
stronger. We therefore expect stronger deleveraging at the VP level
following the current acquisition and related investments executed
at Akropolis. We anticipate S&P Global Ratings-adjusted leverage of
2.4x-2.6x in 2021 and 2.0x-2.5x in 2022. These metrics place the
wider group more soundly at the current rating level in comparison
to Maxima. We believe this further supports our rating on Maxima.

"Maxima's above-industry-average management turnover does not
substantially influence our view of its governance. We note that
Maxima has seen more senior management level changes than the wider
industry average. Although we generally associate frequent changes
with the risk of strategic and operational missteps, we note that
Maxima's operating performance has improved since current CEO
Mantas Kuncaitis took office in October 2020. Moreover, the
majority of the leaving personnel remained part of the group in
different positions. In addition, we note that Maxima's notes are
maturing in September 2023. Although they represent nearly half of
the interest-bearing debt, we currently envisage a smooth
refinancing in first-half 2022, which will support our current
rating. This is supported by the group's now-stronger operating
performance and the bond's current pricing, which is well-above par
in capital markets.

"The stable outlook reflects our expectations that Maxima will
maintain its leading market position in the Baltics despite
intensifying competition, soundly execute planned store expansion
in Poland and Bulgaria, and see normalizing demand for food
following the end of lockdowns, resulting in 4%-8% sales growth and
S&P Global Ratings-adjusted EBITDA margins falling toward, but not
below, 2019 levels. It also takes into account Maxima's prudent
dividend distributions, funded through FOCF, and our expectation of
30%-35% S&P Global Ratings-adjusted funds from operations (FFO) to
debt and about 2.6x-3.0x adjusted debt to EBITDA in 2021 and 2022.
In addition, we expect stronger credit metrics and deleveraging at
the VP group level, with debt to EBITDA of 2.4x-2.6x-x in 2021 and
2.0x-2.5x in 2022, supported by a continued more conservative
financial policy."

S&P could lower the ratings on Maxima if:

-- The company significantly underperforms our base case,
including a material decline in operating performance, with
dropping profitability because of intensifying market competition,
or a weaker macroeconomic environment in the Baltics or Poland,
weighing on margins and cash flows;

-- Maxima's or VP's current financial policies become less
prudent, either due to increased dividends or large-scale,
debt-funded acquisitions that kept leverage at about 3.0x or above
and FFO to debt below 30% at either Maxima or the wider group; or

-- Maxima's or VP's liquidity deteriorates or the senior notes
refinancing is not addressed in a timely manner.

Albeit unlikely over the next 12 months given S&P's understanding
of management's financial policy, it could raise the ratings
following stronger than expected operating performance at Maxima
and the overall VP group. This would include:

-- Adjusted debt to EBITDA falling below 2.0x for Maxima and VP;

-- Maxima's FOCF substantially exceeding actual dividend payments
resulting in debt reduction; and

-- Solid liquidity levels that are maintained.

S&P would also need to see a financial policy commitment from
Maxima and its parent to sustain these credit metrics.




===========
R U S S I A
===========

ROSGOSSTRAKH PJSC: S&P Raises ICR to 'BB+', Outlook Stable
----------------------------------------------------------
S&P Global Ratings raised its long-term issuer credit and financial
strength ratings on Rosgosstrakh PJSC (RGS) to 'BB+' from 'BB'. The
outlook is stable.

The upgrade combines S&P's view of the strengthened
creditworthiness of its parent, Bank Otkritie (BOFC), with the
insurer's stable stand-alone credit characteristics.

More-positive-than-expected economic developments and a faster
recovery have limited the deterioration of Russian banks' asset
quality and supported a rebound in profitability. The banking
system remains adequately capitalized and liquid. S&P believes that
the sector's prolonged correction phase has ended, and now perceive
the system to be in an expansionary phase. As a result, we now
believe that BOFC's credit quality does not negatively influence
that of its subsidiary RGS.

RGS' business risk profile combines a stable market position and
overall satisfactory operating performance in the Russian
property/casualty (P/C) market.

With Russian ruble 49 billion ($0.7 billion) of consolidated
non-life gross written premiums (GWP) for the first six months of
2021, the insurer's market share is 7.2% (the fifth-largest in
Russia's P/C market). Rosgosstrakh has been operating for 100 years
and its business risk profile benefits from strong brand
awareness.

RGS is well diversified in terms of segments: 28% comes from
obligatory motor third-party liability (OMTPL), 23% from personal
accident insurance, 14% from medical insurance, 12% from property
insurance, and 10% from motor hull.

In terms of performance in the OMTPL and medical insurance lines,
the combined ratio for first-half 2021 exceeded 100%. Major factors
driving this performance were harsh winter conditions in Russia in
2020-2021, high payments under the EGARANT system (a special
electronic system for loss-making OMTPL policies), and increased
frequency in the medical insurance line due to the pandemic's
lagging effects.

S&P said, "Overall performance for first-half 2021 is satisfactory,
but weaker than we expected. Net loss grew to 52% and expense 53%
with the combined ratio at 105%, we think that, through end-2021,
RGS will improve its loss ratio, while expenses will stay flat.
However, we expect the insurer will continue to operate with a
combined ratio close to 100% in 2021-2022 and return on equity of
3%-8%.

"We note the negative revaluation of investment portfolio in 2021.
RGS has a high share of bonds in their investment portfolio, and
these were negatively affected by the Central Bank's key rate move,
which increased to 6.75% in October 2021 from 4.25% in March 2021.
We deem this dip in results as temporary and expect better
investment profits in 2022-2023."

RGS' financial risk profile continues to be supported by the
insurer's capitalization, but constrained by the single-name
concentration in its investment portfolio.

S&P expects capitalization will be satisfactory, supported by
investment income but weighed down by portfolio growth and a 30%
dividend payout ratio.

The insurer's regulatory solvency margin under new regulation was
105% (versus the regulatory minimum of 100%) as of July 31, 2021,
but this decline was expected. S&P observes very similar levels for
other large players, and expect an upward trend for RGS through
year-end. The margin improved to 108% as of Sept. 30, 2021, and we
expect it to grow to 118% toward year-end. S&P does not see the
risk of the insurer breaching the minimum regulatory capital
requirements as significant.

Investment-grade bonds issued by the Russian sovereign accounted
for about 27% of RGS' total investment portfolio as of June 30,
2021, and supported weighted-average portfolio quality of close to
the 'BB' category.

As of June 2021, Rosgosstrakh's investment in BOFC were at 36% of
its total reported equity versus 73% of reported capital as of Dec.
31, 2020. This concertation will continue to decrease due to
tightening regulation.

While the creditworthiness of RGS and BOFC are interlinked, RGS
operates separately from BOFC, and its financial performance and
funding are highly independent from its parent's. RGS does not have
any significant operational dependence on the group's other
entities. The insurer maintains its own records and funding
arrangements and does not commingle funds, assets, or cash flows
with BOFC. There is a strong economic basis for BOFC and the
Central Bank to preserve RGS' credit strength.

S&P said, "While we continue to view RGS as a government-related
entity, our view of the likelihood of government support is now
low, considering the Central Bank's plans to sell part of its full
stake in RGS or BOFC.

"The stable outlook reflects our expectation that RGS will continue
to show satisfactory capital through profit retention over the next
12 months, with stable business volumes in 2021 and 2022. Our
capital forecast includes 70% profit retention in 2020-2023 and no
extraordinary dividends."

An upgrade is unlikely considering the comparison with
more-established and better-capitalized peers.

S&P said, "We would downgrade RGS if its underwriting performance
were significantly weaker than expected or capital adequacy
significantly deteriorated. We could also lower the issuer credit
rating on RGS if the BOFC group's credit quality were to
deteriorate, which is not our base-case scenario.

"We could consider a downgrade if, because of any planned
privatization, RGS is owned by an entity with lower credit standing
and we believe that the insurer's credit quality is not properly
insulated."


UZBEKNEFTEGAZ JSC: S&P Assigns 'BB-' ICR, Outlook Stable
--------------------------------------------------------
S&P Global Ratings assigned its 'BB-' long-term issuer credit
rating to Uzbekistan's national integrated oil and gas producer
Uzbekneftegaz JSC.

The stable outlook reflects S&P's expectation that increasing
EBITDA, on the back of GTL ramp-up, should offset anticipated debt
build-up to finance capex and allow the company to maintain funds
from operations (FFO) to debt at 13%-18% in the forecast period.

The 'BB-' rating balances Uzbekneftegaz's moderate size, low
profitability, and currently high leverage with stability of its
cash flows, deleveraging prospects and state support. Uzbekneftegaz
is a midsize integrated energy producer with large exposure to gas,
which the company mostly supplies to the domestic market at
regulated prices. The prices, currently fixed at about $34 per
thousand cubic meters (/kcm), limit cash flow generation and result
in weak profitability, but ensure lower volatility than most of its
peers. The rating captures Uzbekneftegaz's relatively high leverage
due to significant capital investments, but also accounts for the
potential improvement in credit metrics as these large projects
ramp up. Finally, it reflects S&P's expectation of an extremely
high likelihood of government support based on the company's
critical role for the local economy and significant share of the
debt being state-guaranteed.

Uzbekneftegaz's leverage will gradually decline, despite sizable
capital investments in the coming years, as GTL becomes fully
operational in 2022 and contributes to EBITDA growth. Uzbekneftegaz
plans a significant capex program of $1.8 billion to expand the
Shurtan gas chemical complex (GCC), to produce up to 400,000 metric
tons (mt) of polyethylene and 100,000 mt of polypropylene and
adding as much as $200 million of EBITDA with an estimated start in
2024. This will lead to negative discretionary cash flow generation
and debt accumulation in the next few years. However, this will be
offset by the EBITDA growth toward $1.3 billion by 2023 from $900
million forecast in 2021, primarily driven by the EBITDA
contribution from GTL, which S&P expects to ramp up toward the end
of 2021. The $3.6 billion plant will convert low cost gas into
value-added products such as diesel, naphtha, and jet fuel,
providing substitutes for those products that are currently
imported in the domestic market. As a result, S&P expects FFO to
debt to improve to 18% from 13% by 2023.

S&P said, "We do not factor in our rating the potential
liberalization of the domestic gas market, which could lead to
significant improvement in credit metrics, because the timing of
the reform is still to be clarified.We understand that Uzbekistan's
government plans to revise fixed gas tariffs to a more competitive
level, which could significantly improve the company's cash
generation and profitability, while almost doubling EBITDA.
However, until the timing and major steps of the reform are clear,
we will not include it in our base-case forecast. Moreover, we will
require a certain track record of performance under the new tariff
system to ensure the domestic economy is capable of bearing
increased costs and that payment collection does not deteriorate.
We would also review the group's financials and dividends in such a
case, as the group's capacity for investments and dividends would
increase."

Uzbekneftegaz's low profitability and asset concentration in
high-country-risk Uzbekistan are somewhat offset by its sizable,
low-cost production and fixed gas tariffs. Uzbekneftegaz is a
national oil and gas producer with assets concentrated in
Uzbekistan, producing 36 billion cm of gas as of 2020 and
extracting 67% of the country's gas. S&P sees the company's
production scale of about 540,000 barrels of oil equivalent per day
(boepd) in 2020 as in line with national producers in the region,
like KMG NC (BB/Negative) with 485,000 boepd or PTT Exploration and
Production (BBB+/Stable) with 354,000 boepd. However, for a
comparable production level, Uzbekneftegaz generates about $1
billion EBITDA , which is 3x lower than that of KMG NC. This is
because 85% of EBITDA is generated from gas sales, which are
realized domestically at a low fixed tariffs. The company sells gas
for about $34/kcm, which is lower than domestic prices in Russia of
about $60/kcm. or the regional export price of about $100/kcm. This
translates into weaker profitability, but results in significantly
lower volatility compared with peers. We further note a good
reserve base that ensures at least 11 years of production and high
quality of reserves. As per S&P's estimates, Uzbekneftegaz benefits
from low cost of gas production of about $8/kcm-$9/kcm, comparable
with $6/kcm at another cost leader, Gazprom. Moreover, the rating
assessment reflects the general risks associated with operations in
Uzbekistan.

The company's exposure to foreign-exchange (FX) risk will reduce
with the GTL refinery launch and Shurtan GCC expansion.
Uzbekneftegaz currently generates almost no revenue from export
operations, selling gas and refined products domestically in local
currency. However, in 2020 Uzbekistan's government liberalized
refined product prices, which are now linked to global oil prices.
The GTL launch should significantly increase the share of revenue
linked to U.S. dollars, with the refining segment's EBITDA
contribution increasing to up to 40% from 6% in 2020 as the
refinery fully ramps up. This will further improve with expansion
of the Shurtan GCC with an estimated start in 2024, because most of
the chemicals will be exported. The increasing share of revenue
linked to hard currency should significantly reduce the company's
existing exposure to FX risk, because 90% of debt is denominated in
U.S. dollars. Any further devaluation of the local currency would
only support the company's cost position.

S&P said, "Our assessment of an extremely high likelihood of
extraordinary state support reflects the company's critical role to
the domestic economy, but does not lead to automatic rating
alignment. Uzbekneftegaz supplies a large share of gas and refined
products to the domestic economy and realizes gas at significantly
lower prices than regional peers, ensuring affordable consumption
and cheap input for the industrial sector. We positively note a
track record of support, including a $1.7 billion recapitalization
in 2020, liberalization of oil product prices, and a guarantee
provision for about 80% of debt, which is the highest proportion
among all national oil companies that we rate. In our base case, we
don't forecast the government will meaningfully reduce its stake in
Uzbekneftegaz from the current 99.94% in the near term and expect
it will continue to fully control the company's strategy through
its board representation. At the same time, our assessment is
limited by the government's longer-term plans to further liberalize
the gas market and transform the state-owned company to a
competitive and more independent gas producer.

"The stable outlook on Uzbekneftegaz reflects our expectation that
the company will secure financing for its large capex program and
successfully ramp up the GTL plant with no material cost overruns
or delays. In our base case, a successful GTL launch should support
the company's metrics, and FFO to debt should remain at about 13%
in 2021, gradually rising to 15%-18% by 2023. We also expect no
changes in gas tariff regulation, ensuring stable cash generation
from the gas sales."

The rating on Uzbekneftegaz is capped by the sovereign rating on
Uzbekistan.

Rating upside would be possible through a combination of a
sovereign upgrade and a stronger stand-alone credit profile (SACP).
However, SACP upside is limited in the near term under current gas
tariff regulation and our expectation that leverage will remain
high in the coming years as the expansion program progresses. An
upward revision of gas tariffs could therefore be an important
driver for a stronger SACP, but only if combined with a commitment
to maintain lower leverage through the cycle.

S&P could downgrade Uzbekneftegaz if:

-- S&P downgrades the sovereign, given its rating is capped by
that on Uzbekistan.

-- FFO to debt deteriorates to below 12%, which could likely be
due to a GTL launch delay or Shurtan GCC expansion cost revisions.

-- The company cannot raise long-term debt to finance capex, which
would pressure liquidity.




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

TURKEY: S&P Affirms 'B+/B' Unsolicited Sovereign Credit Ratings
---------------------------------------------------------------
S&P Global Ratings, on Oct. 22, 2021, affirmed its unsolicited
'B+/B' long- and short-term foreign currency sovereign credit
ratings on Turkey and its unsolicited 'BB-/B' long- and short-term
local currency sovereign credit ratings. The outlook is stable. S&P
also affirmed the unsolicited national scale ratings at
'trAA+/trA-1+'.

Outlook

The stable outlook considers the lingering risks from Turkey's
economic imbalances over the next 12 months. These are partly
offset by the resilience of Turkey's private sector and the
manageable stock of net general government debt, which leaves room
for a fiscal policy response, should one be required.

Downside scenario

S&P said, "We could lower the ratings if we saw a heightened risk
of banking system distress, implying potential contingent
liabilities for the government. This could be the case, for
example, if banks' access to foreign funding deteriorated, or
domestic residents dollarized their savings further, which is not
our base-case scenario. Weakened asset quality following the
large-scale credit stimulus in 2020 could also put pressure on the
banking system, particularly state-owned banks that saw their
balance sheets expand more rapidly last year."

Upside scenario

S&P said, "We could consider an upgrade if Turkey's
balance-of-payments position strengthened beyond our projections,
particularly the central bank's net foreign-exchange reserves. We
could also raise the ratings if we observed sustained and enhanced
predictability of public policy and effectiveness of monetary
policy."

Rationale

S&P said, "Our ratings on Turkey remain supported by its
diversified economy and resilient and adaptive private sector,
which, in the past, has weathered external shocks, currency
volatility, and frequent changes in economic policy. The ratings
are also supported by contained net general government debt, which
we forecast will amount to 34% of GDP by the end of 2021.

"Our ratings on Turkey are constrained by its vulnerable
balance-of-payments position and the limited effectiveness of its
monetary policy. The ratings are also restricted by what we view as
weak institutional arrangements. We see limited checks and balances
between government bodies, with power concentrated in the hands of
the executive branch, which renders policy responses difficult to
predict."

Institutional and economic profile: The post-pandemic recovery is
strong, but the risk of policy missteps is high

-- Turkey's economy has recovered faster than those of other
emerging markets, with real output already 8.4% above the
pre-pandemic peak as of the second quarter of 2021.

-- However, this comes partly at the price of wider economic
imbalances, such as high inflation and lower useable
foreign-exchange reserves at the central bank.

-- Turkey's institutional arrangements are weak, and its future
policy direction remains uncertain, particularly in light of the
upcoming general elections in 2023.

The Turkish economy rebounded briskly from a pandemic-related
downturn last year, and has continued to expand in 2021. In real
terms, output had already exceeded the pre-pandemic peak in the
third quarter of 2020, and now stands 8.4% above the pre-pandemic
level attained in the first quarter of 2020.

S&P said, "In our view, the direct risks that the COVID-19 pandemic
poses for the Turkish economy are now receding. To date, Turkey has
fully vaccinated more than 55% of its population, with almost 65%
having received at least one jab. Although new cases and deaths
have risen significantly since mid-summer 2021, they appear to be
mostly among the non-vaccinated. Almost all restrictions on social
contact were lifted in July 2021, and we do not expect any new
restrictions to be introduced, although some risks from the
emergence and spread of new virus variants remain."

The lifting of pandemic-related restrictions, as well as the
removal of Turkey from red travel lists by several EU countries,
the U.K., and Russia, has allowed tourism to restart, boosting
service exports. Over May to August 2021, travel income from
visitors from abroad amounted to $7.7 billion, rising from under $2
billion for the same period last year, when the industry came to a
halt. Overall, revenue from international travel amounted to $10.5
billion in the year to August 2021, and S&P thinks this could rise
toward $17 billion-$18 billion for the full year. This would be
equivalent to about 70% growth compared to 2020, but still about
40% less than the 2019 outturn of almost $30 billion. S&P expects
that it will take until 2023 for the sector to recover to the
pre-pandemic base.

Despite the strong recovery, in our view, policymaking in Turkey is
frequently inconsistent and unpredictable. Institutional changes
over the past several years have affected the independence of key
institutions. Since the government amended the law on the Central
Bank of the Republic of Turkey (CBRT) by statutory decree in July
2018, the Turkish president's influence over the CBRT has been in
the ascendant. Under the amendments, the president determines the
salaries of the CBRT board members, and has the power to intervene
in CBRT decisions in the event of disagreement between the governor
and the board members.

Consequently, the CBRT's focus on its price stability mandate
appears to have weakened. In September this year, consumer
inflation rose to a two-year high of 19.6% year on year, which is
four times the CBRT's 5% target. Against that backdrop, the CBRT
still decided to lower interest rates by 100 basis points.
Subsequently, the president reshuffled personnel at the CBRT yet
again, dismissing two deputy governors and a third member of the
monetary policy committee who had reportedly expressed reservations
about premature interest rate cuts. Following that, the CBRT
delivered a further significant 200 basis-point rate cut, leading
to further depreciation of the lira. At 16%, the policy rate is
lower than headline inflation, making the real rate effectively
negative once again.

S&P considers that political pressure on the CBRT will continue,
increasing the likelihood of further loosening of monetary policy,
whether justified by the economic fundamentals or not. This brings
risks of further volatility in the foreign-currency market, adding
to inflationary pressures, with negative secondary effects for
asset quality, and potentially for growth. The present misalignment
between monetary policy and inflation could also ultimately force
the central bank to abruptly reverse course, as it did in 2018 and
2020, hiking up rates significantly following previous policy
loosening. Such an outcome could drag on growth. Additionally, the
weaker Turkish lira increases the pressure on the domestic
corporate sector, which has a sizable amount of foreign
currency-denominated debt outstanding.

S&P also thinks that policy missteps could stem from the 2023
general elections. Recent opinion polls suggest declining popular
support for the ruling Justice and Development Party (Adalet ve
Kalkinma Partisi; AKP), with the pandemic, high inflation in food
prices, and a hit to real incomes likely to be contributing
factors. In that context, additional policy-stimulus measures--for
example, to boost the availability or reduce the price of
credit--cannot be ruled out next year, even though Turkey still
faces lingering imbalances from previous such measures, including
lower useable foreign-exchange reserves and higher inflation.

In S&P's view, supply-chain disruptions and higher energy prices
could drag on the recovery, as Turkey is an energy-importing
economy. Additionally, the gradual phase-out of accommodative
monetary policy by central banks in developed markets, which
underpinned much of the flow of funds to emerging markets, could
expose Turkey's imbalances.

S&P said, "Overall, based on the actual outturn for the second
quarter of 2021, we have revised our growth projection for this
year up to a high 8.6%. However, this is underpinned to a large
degree by statistical carryover effects and masks a likely
quarterly slowdown. Beyond 2021, our annual growth projections
remain largely unchanged at around 3%. We do not consider this
particularly strong on a per capita basis, given Turkey's steady
population growth, which has averaged 1.2% annually over the past
five years. In our view, medium-term growth rates will be held back
by the persistent unpredictability of economic policy and domestic
political developments, which will stunt the flow of foreign direct
and portfolio investment.

"Aside from the general direction of its economic policy, we still
consider that Turkey's broader institutional arrangements remain
weak and continue to constrain the sovereign credit ratings. In the
June 2018 presidential and parliamentary elections, the president
and the AKP-led alliance secured a victory that marked the final
chapter in Turkey's transition to an executive presidential system.
We see limited checks and balances between government bodies."

Flexibility and performance profile: Fiscal space partly offsets
the weak balance of payments and limited effectiveness of monetary
policy

-- Turkey's external imbalances have moderated but remain high,
characterized by high external financing requirements and contained
usable international reserves.

-- S&P forecasts that Turkey's net general government debt will
stabilize at close to 33% of GDP over the medium term, which is
still low compared with many other emerging markets.

-- Monetary policy effectiveness is constrained by what S&P views
as the limited operational independence of the CBRT, with
double-digit inflation rising to 19.6% year on year in September
2021, the highest in 2.5 years.

Turkey's external imbalances remain elevated, but they have
moderated since the highs in 2020. In U.S. dollar terms, over the
first eight months of 2021, the current account deficit halved to
$14 billion (1.9% of full-year GDP), chiefly supported by:

-- A pronounced reduction in nonmonetary gold imports to $4.5
billion from last year's $15 billion; and

-- Recuperating trade in services, primarily international travel,
with the balance of services rising to $12.5 billion from last
year's $6 billion.

S&P forecasts that the current account deficit will amount to just
under $20 billion for the full year, equivalent to 2.6% of GDP.

The central bank's gross foreign-exchange reserves have also grown,
from $93 billion at the end of 2020 to just over $120 billion at
the start of October 2021. The following factors contributed to
this:

-- The CBRT's rediscount credit facility, whereby loans are
provided to exporters in local currency but are repaid in foreign
currency;

-- Turkey's conclusion of additional swap agreements with foreign
counterparties, including the People's Bank of China and the Bank
of Korea; and

-- The IMF's allocation of special drawing rights worth $6.3
billion.

S&P said, "Nevertheless, we still view vulnerabilities in the
balance of payments as elevated. Once domestic swaps and commercial
banks' required foreign-currency reserves at the CBRT are netted
out, the net useable foreign-exchange reserves amount to a much
smaller $34 billion (4.5% of GDP). This compares with close to $170
billion (23% of GDP) of foreign debt that Turkey needs to roll over
in the next 12 months, much of it within the banking system.

"In contrast, Turkey's fiscal position remains strong compared to
many other emerging markets and continues to support the sovereign
credit ratings. Most of last year's pandemic-related support
measures came in the form of credit provisions, and the general
government deficit amounted to 2.9% of GDP, lower than we
previously estimated. However, the increase in public leverage was
higher, primarily because of depreciation of the Turkish lira, as
over half of government debt is now denominated in foreign
currencies. In addition, in May 2020, the government injected
capital worth 0.5% of GDP into state banks via the sovereign wealth
fund.

"We estimate that the fiscal deficit will narrow to 2.5% of GDP in
2021, given the economic recovery and the withdrawal of some of the
pandemic-related support measures. The government has also recently
increased the corporate income tax, which should bolster revenue.

"We project that net general government debt will total 34% of GDP
by the end of 2021, which is modest for an emerging market, and
leaves the government with room to loosen its fiscal policy in an
adverse economic scenario. The government has issued Eurobonds on
multiple occasions in recent months, demonstrating access to the
international capital market. The focus has also recently shifted
toward issuing domestic debt with longer maturities and in local
currency.

"Although fiscal leverage remains low, we see risks from contingent
liabilities. We anticipate that the government may have to support
the financial sector, particularly the public banks. Two cases of
recapitalization have already occurred over the past two years
(0.7% of GDP in April 2019 and 0.5% of GDP in May 2020). Additional
support may be required as a consequence of last year's rapid loan
growth and the more recent volatility in the exchange rate.

"In our view, banks' reportedly strong asset quality, with
nonperforming loans below 4% of total loans, underestimates the
true underlying credit quality of the loan book. We still expect
asset quality to deteriorate, particularly as forbearance and
support measures are withdrawn, and as a large stock of credit that
banks extended last year starts to mature." In mid-October 2021,
the global Financial Action Task Force grey-listed Turkey, citing
supervision issues relating to the prevention of money laundering
and terrorism financing.

Still, over the past two years, Turkish banks have been
consistently able to roll over their foreign debt coming due,
including during difficult times. This was evident following the
August 2018 currency crisis and immediately after the onset of the
pandemic in 2020, at the height of the uncertainty. In recent
years, domestic residents have been gradually shifting their
savings into foreign currencies and gold, but have maintained
confidence in the financial system without any sizable deposit
withdrawals. S&P expects this to remain the case.

Turkey's monetary policy has historically been ineffective at
managing inflation. The CBRT has never met the 5% medium-term
target it introduced in 2012, while Turkey's real effective
exchange rate has fluctuated substantially. The CBRT has faced
increasing political pressure in recent years, which has frequently
delayed timely responses to rising inflation. S&P siad, "We
consider that the central bank will face further pressure to
accelerate the rate-easing cycle following a 100 basis-point cut in
interest rates in September 2021 and another 200 basis-point cut in
October. We forecast that inflation will average 17.3% this year,
falling to 12% in 2022, but there is a risk that it could be
higher."

In accordance with S&P's relevant policies and procedures, the
Rating Committee was composed of analysts that are qualified to
vote in the committee, with sufficient experience to convey the
appropriate level of knowledge and understanding of the methodology
applicable. At the onset of the committee, the chair confirmed that
the information provided to the Rating Committee by the primary
analyst had been distributed in a timely manner and was sufficient
for Committee members to make an informed decision.

After the primary analyst gave opening remarks and explained the
recommendation, the Committee discussed key rating factors and
critical issues in accordance with the relevant criteria.
Qualitative and quantitative risk factors were considered and
discussed, looking at track-record and forecasts.

The committee's assessment of the key rating factors is reflected
in the Ratings Score Snapshot above.

The chair ensured every voting member was given the opportunity to
articulate his/her opinion. The chair or designee reviewed the
draft report to ensure consistency with the Committee decision. The
views and the decision of the rating committee are summarized in
the above rationale and outlook. The weighting of all rating
factors is described in the methodology used in this rating
action.

  Ratings List

  RATINGS AFFIRMED

  TURKEY

  Sovereign Credit Rating

   Foreign Currency |U^      B+/Stable/B
   Local Currency |U^        BB-/Stable/B
   Turkey National Scale |U^ trAA+/--/trA-1+

  Transfer & Convertibility Assessment

   Local Currency |U^        BB-

|U^ Unsolicited ratings with issuer participation, access to
internal documents and access to management.




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

ASDA: Taps Barclays to Raise GBP500MM Debt to Repay Bridge Loan
---------------------------------------------------------------
Laura Benitez at Bloomberg News reports that Barclays Plc is
leading a round of talks with investors to raise the equivalent of
GBP500 million (US$691 million) of debt for U.K. supermarket chain
Asda after a deal to purchase its forecourt gas pumps business fell
through.

The bank is seeking to raise senior secured debt for Asda which
could be a mix of bonds and loans, Bloomberg relays, citing people
familiar with the matter.  The proceeds, along with GBP262 million
on Asda's balance sheet, will go to repay a GBP750 million bridge
loan, Bloomberg states.

The fundraising comes with the supermarket unable to rely on
proceeds from the gas stations' sale after EG Group and Asda, both
owned by Mohsin and Zuber Issa, said earlier this week that they'd
scrapped the planned GBP750-million transaction after reviewing
commercial information, Bloomberg notes.

The Issa brothers, along with TDR Capital, struck a GBP6.8-billion
deal a year ago to buy Asda from Walmart Inc., Bloomberg recounts.
Their EG Group later separately agreed to buy Asda's gas filling
stations, car washes and ancillary land.

Around GBP6.4 billion of financing is expected to launch to the
public market to finance the deal, Bloomberg discloses.


DERBY COUNTY FOOTBALL: Have Two "Very Serious, Credible Offers"
---------------------------------------------------------------
Sarah Clapson at NottinghamshireLive reports that Nottingham
Forest's arch-rivals Derby County Football Club is said to have two
"very serious and credible offers" to buy the club.

The Rams are bottom of the Championship table, having been deducted
12 points after they went into administration five weeks ago,
NottinghamshireLive relates.

According to NottinghamshireLive, Andrew Hosking and Carl Jackson
of business advisory firm Quantuma were installed as
joint-administrators and they set about finding a buyer for the
club.

The message from the outset was of a number of potential purchasers
showing considerable interest, NottinghamshireLive notes.

And, according to The Transfer Window Podcast, boss Wayne Rooney
has been told he should start planning for the January transfer
window, as football journalists Ian McGarry and Duncan Castles
discussed the situation, NottinghamshireLive states.

According to NottinghamshireLive, Mr. McGarry claimed: "Derby
County, their administrators have assured Wayne Rooney and his
coaching staff that they have two very serious and credible offers
to buy the club and that they should start to prepare plans for
recruitment in January, which of course has not been something they
have been able to do until now.

"There is money available apparently and potentially for transfer
fees and for contracts for new players, and they are looking for
two strikers and an attacking wide midfielder.

"Obviously Derby have suffered the 12-point deduction for going
into administration which has left them bottom of the division but
the results have been relatively remarkable, I suppose you could
say, in the circumstances.

"Maybe, just maybe they are going to turn the corner."

Mr. Castle, as cited by NottinghamshireLive, said: "It is a big
task ahead of them with that points penalty.

"Whoever takes that club on and is prepared to invest significant
money in transfers is taking on a risk.

"It is a significant task ahead of Wayne Rooney and his coaching
staff to try and keep them up regardless of whether there is going
to be investment in the team rapidly and quickly enough to bring
players in in January or not."

               About Derby County Football Club

Founded in 1884, Derby County Football Club is a professional
association football club based in Derby, Derbyshire, England.  The
club competes in the English Football League Championship (EFL, the
'Championship'), the second tier of English football.  The team
gets its nickname, The Rams, to show tribute to its links with the
First Regiment of Derby Militia, which took a ram as its mascot.
Mel Morris is the owner while Wayne Rooney is the manager of the
club.  

On Sept. 22, 2021, the club went into administration.  The EFL
sanctioned a 12-point deduction on the club, putting the team at
the bottom of the Championship.  Andrew Hosking, Carl Jackson and
Andrew Andronikou, managing directors at business advisory firm
Quantuma, had been appointed joint administrators to the club.


ELLIOT GROUP: Investors' Cash Used to Make Unsecured Loans
----------------------------------------------------------
Tom Duffy at Echo reports that investors have expressed concern
over the way in which a property developer used their deposits to
make unsecured loans.

Investors in the Infinity Waters scheme on Leeds Street told of
their guilt, shame and anxiety following the collapse of the
scheme, Echo relates.

Elliot Group schemes Infinity Waters, Aura and The Residence all
entered into administration last year, Echo recounts.

Liverpool businessman Elliot Lawless, who founded the group, has
said that his arrest in December 2019 on suspicion of conspiracy to
defraud, bribery and corruption led to the collapse of the
ventures, Echo notes.

The police investigation is continuing, but Mr. Lawless denies any
wrongdoing, Echo discloses.

Following an investigation into the Elliot Group the Liverpool ECHO
can now reveal that Mr. Lawless used investors money to make large
unsecured loans to associated companies in 2019, Echo recounts.

According to Echo, statutory documentation filed at Companies House
shows the various inter-company loans were made before December
2019.

Over GBP4 million was loaned, without security, by the Residence
and Infinity companies to the Aura company alone, Echo states.

The Residence scheme lent GBP3.5 million to the Aura venture, and
Infinity Waters lent GBP746,000 to Aura, Echo notes.  The loans
were unsecured in that they were not protected by debentures,
according to Echo.

The Equity Group Limited, a company controlled by Mr. Lawless, lent
the Aura company GBP6,415,634 in 2019, Echo recounts.  This loan,
which did not involve investors' cash, was however protected by a
debenture, according to Echo.

Statutory documentation filed at Companies House shows that the
Infinity company received GBP28 million from investors who put down
deposits, Echo discloses.

The site was acquired for around GBP5050,000, and fees came to
around GBP4.67 million, according to Echo.  Investors put in around
GBP27, 292,872 but it is not yet clear how much was paid to
builders Vermont, Echo states.

The investors received notification that finance company Maslow
Capital were providing funding in September 2019 but it is now
clear that Maslow did not follow through with a loan, Echo relays.

Mr. Lawless also sold a large share in Infinity Waters site to a
sister company, Echo discloses.  Land was transferred from
Queensland Place to the Elliot Group and from Parliament Place to
1DOM, Echo recounts.


EUROSAIL PLC 2006-2BL: Fitch Affirms CCC Rating on Class F1c Debt
-----------------------------------------------------------------
Fitch Ratings has affirmed all tranches of Eurosail 2006-2BL Plc
(ES06-2) and Eurosail 2006-4NP Plc (ES06-4), while revising the
Outlooks on five junior notes to Stable from Negative.

        DEBT                   RATING           PRIOR
        ----                   ------           -----
Eurosail 2006-2BL PLC

Class A2c XS0266235612    LT AAAsf  Affirmed    AAAsf
Class B1a XS0266238715    LT AAAsf  Affirmed    AAAsf
Class B1b XS0266244440    LT AAAsf  Affirmed    AAAsf
Class C1a XS0266246817    LT AAAsf  Affirmed    AAAsf
Class C1c XS0266250413    LT AAAsf  Affirmed    AAAsf
Class D1a XS0266252625    LT AA-sf  Affirmed    AA-sf
Class D1c XS0266256709    LT AA-sf  Affirmed    AA-sf
Class E1c XS0266258317    LT BB-sf  Affirmed    BB-sf
Class F1c XS0266260560    LT CCCsf  Affirmed    CCCsf

Eurosail 2006-4NP Plc

Class A3a XS0275909934    LT AAAsf  Affirmed    AAAsf
Class A3c XS0275917796    LT AAAsf  Affirmed    AAAsf
Class B1a XS0274201507    LT AAAsf  Affirmed    AAAsf
Class C1a XS0274203891    LT AAAsf  Affirmed    AAAsf
Class C1c XS0274213692    LT AAAsf  Affirmed    AAAsf
Class D1a XS0274204196    LT A-sf   Affirmed    A-sf
Class D1c XS0274214310    LT A-sf   Affirmed    A-sf
Class E1c 027421601       LT CCCsf  Affirmed    CCCsf
Class M1a XS0275920071    LT AAAsf  Affirmed    AAAsf
Class M1c XS0275921715    LT AAAsf  Affirmed    AAAsf

TRANSACTION SUMMARY

The transactions comprise non-conforming UK mortgage loans
originated by Southern Pacific Mortgage Limited and Preferred
Mortgages Limited, formerly wholly owned subsidiaries of Lehman
Brothers.

KEY RATING DRIVERS

Increased Late-Stage Arrears

Total arrears in both transactions have been falling from the
levels reached during 2020, with total arrears at 22.9% for ES06-2
and 16.5% for ES06-4 in September 2021 compared to 25.1% and 19.0%
as at September 2020. However, both transactions have reported a
moderate accumulation of late-stage arrears, with loans in arrears
by more than three months representing 18.5% and 12.3% of the
mortgage pools for ES06-2 and ES06-4, increases of 2.1% and 0.8%,
respectively, from September 2020.

The rise in late-stage arrears is partially due to the moratorium
on repossessions implemented during the pandemic. The moratorium
restricted servicers' ability to proceed with repossession orders,
leading to increased late-stage arrears that would ordinarily have
been foreclosed.

Credit Enhancement Accumulation

Credit enhancement (CE) has increased in both transactions as they
continue to amortise sequentially due to late-stage arrears trigger
breaches. CE available for the senior notes has increased to 88.1%
for ES06-2 and 90.9% for ES06-4, respectively. This is well above
CE levels of 80.3% and 80.0% as at the last review in October
2020.

Foreclosure Frequency Macroeconomic Adjustments

Fitch applied foreclosure frequency (FF) macroeconomic adjustments
to the UK non-conforming sub-pool of both transactions because of
the expectation of a temporary mortgage underperformance (see
"Fitch Ratings to Apply Macroeconomic Adjustments for UK
Non-Conforming RMBS to Replace Additional Stress"). With the
government's repossession ban ended, there is still uncertainty
about the borrowers' performance in the non-conforming sector where
many borrowers have already rolled into late arrears over recent
months.

Borrowers' payment ability may also be challenged with the end of
the Coronavirus Job Retention Scheme and Self-employed Income
Support Schemes. The adjustment is of 1.58x at 'Bsf', while no
adjustment is applied at 'AAAsf' as assumptions are deemed
sufficiently remote at this level.

Performance Adjustment Factor

Fitch has applied a floor to the performance adjustment factor
(PAF) of 100% for each of the owner-occupied sub-pools to reflect
the back-loaded default risk associated with interest-only loans.
For the buy-to-let sub pools, Fitch applied a floor in the PAF of
185% in ES06-2 and 161% in ES06-4. These floors prevent a reduction
in performance adjustment that would otherwise occur in Fitch's
ResiGlobal Model: UK as a result of the calculated PAF reducing due
to increased late-stage arrears.

Increased Interest-Only Loans Past Maturity

There has been an increase in the proportion of interest-only loans
that have been unable to make their bullet payment and exceeded
their scheduled maturity. These loans now represent 4% of the
ES06-2 pool and 5% of the ES06-4 pool. In addition in most
instances a material amount (greater than or equal to 5%) of the
original loan balance remains outstanding and may be unlikely to be
repaid within 12 months.

To account for this, a four-year maturity extension on these loans
was assumed, delaying the receipt of principal redemptions to the
issuer. Fitch applies an upward adjustment to the foreclosure
frequency of interest-only loans based on the indexed CLTV and
remaining term to maturity as set out in its "UK RMBS Rating
Criteria".

Increased Senior Fees

Both transactions have been incurring an increased level of senior
fees since 2018. Fitch has reflected this increase in its fee
assumptions for the transaction by assuming that the average of the
costs incurred in the last three years will continue.

In Fitch's opinion the combination of increasing late-stage
arrears, increasing interest-only loans past maturity and
increasing senior fees may lead to model implied ratings (MIR)
being lower in future model updates. As a result Fitch has
constrained the rating of classes D and E in ES06-2 one notch below
and the class D in ES06-4 two notches below the MIR.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- The transactions' performance may be affected by changes in
    market conditions and economic environment. Weakening economic
    performance is strongly correlated to increasing levels of
    delinquencies and defaults that could reduce CE available to
    the notes.

-- Unexpected declines in recoveries could also result in lower
    net proceeds, which may make certain notes susceptible to
    negative rating action depending on the extent of the decline
    in recoveries. Fitch conducts sensitivity analyses by
    stressing both a transaction's base-case FF and recovery rate
    (RR) assumptions, and examining the rating implications on all
    classes of issued notes. Fitch considered a scenario assuming
    a 15% increase in the WAFF and a 15% decrease in the WARR
    would result in downgrades of up to five notches.

Factor that could, individually or collectively, lead to positive
rating action/upgrade:

-- Stable to improved asset performance driven by stable
    delinquencies and defaults would lead to increasing CE levels
    and potential upgrades. Fitch tested an additional rating
    sensitivity scenario by applying a decrease in the FF of 15%
    and an increase in the RR of 15%. The ratings for the
    subordinated notes could be upgraded by up to eight notches.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset
pools and the transactions. Fitch has not reviewed the results of
any third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

Fitch did not undertake a review of the information provided about
the underlying asset pools ahead of the transaction's initial
closing. The subsequent performance of the transactions over the
years is consistent with the agency's expectations given the
operating environment and Fitch is therefore satisfied that the
asset pool information relied upon for its initial rating analysis
was adequately reliable.

Overall, Fitch's assessment of the information relied upon for the
agency's rating analysis according to its applicable rating
methodologies indicates that it is adequately reliable.

ESG CONSIDERATIONS

ES06-2 and ES06-4 have an ESG Relevance Score of 4 for Human
Rights, Community Relations, Access & Affordability due to a
significant proportion of the pools containing owner-occupied loans
advanced with limited affordability checks, which has a negative
impact on the credit profile, and is relevant to the ratings in
conjunction with other factors.

ES06-2 and ES06-4 have an ESG Relevance Score of 4 for Customer
Welfare - Fair Messaging, Privacy & Data Security due to the pools
having an interest-only maturity concentration of legacy
non-conforming owner-occupied loans of greater than 20%, which has
a negative impact on the credit profile, and is relevant to the
rating, in conjunction with other factors.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.


PROVIDENT FINANCIAL: Fitch Gives Final 'B+' Rating to Tier 2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned Provident Financial Plc's (Provident,
BB/negative) issue of 8.875% Tier 2 notes, valued at GBP200
million, a final rating of 'B+'. The notes will mature 13 January
2032. Proceeds from the issuance were partially used to early repay
outstanding senior debt (GBP72 million), and the remainder will be
used for general corporate purposes.

The assignment of the final rating follows the receipt of documents
conforming to information already received. The final rating is the
same as the expected rating assigned to the senior secured term
loan on 11 October 2021.

KEY RATING DRIVERS

The Tier 2 notes' rating is two notches below Provident's Long-Term
Issuer Default Rating (IDR), reflecting poor recovery prospects in
the event of a failure of Provident, in line with Fitch's base-case
notching for Tier 2 debt. Fitch has not applied additional notching
as the issue terms do not contain features that give rise to
incremental non-performance risk.

In line with standard Tier 2 notes issued by UK banks and non-banks
such as Provident subject to bank-like prudential requirements, the
relevant resolution authority (the Bank of England) can resolve
Provident (and mandatorily write down or convert the notes into
equity) should Provident meet the conditions for resolution. In
addition, through its statutory powers the UK resolution authority
can override the bonds' contractual terms if it considers it
necessary to restore the viability of the group's core subsidiary,
Vanquis Bank.

Provident is prudentially regulated and is issuing the bonds on its
own balance sheet (rather than on Vanquis Bank).

RATING SENSITIVITIES

The rating of the Tier 2 notes is primarily sensitive to movements
in Provident's Long-Term IDR.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

The issue rating could be downgraded if Provident's IDR is
downgraded, namely in a scenario of:

-- Further adverse developments from the pandemic or regulatory
    developments in the UK high-cost credit sector, including
    materially higher-than-anticipated costs relating to the
    ongoing scheme of arrangement, aimed at winding down
    Provident's home-collected credit business.

-- Prolonged measures capping interest rates, constraining new
    lending or debt servicing and therefore eroding earnings
    capacity.

-- Significant deterioration of solvency as manifested in reduced
    regulatory capital headroom with capital ratio approaching
    regulatory capital requirement.

-- A notable weakening of the liquidity profile.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

The issue rating could be upgraded if Provident's IDR is upgraded:

-- The Outlook on Provident's Long-Term IDR could be revised to
    Stable if pandemic-related disruptions abate and regulatory
    risks moderate, supporting a more stable business model,
    particularly if in conjunction with improved earnings and
    stable leverage.

-- Upside for Porvident's ratings is limited in the short term
    due to moderate scale (compared with higher-rated peers) and
    Fitch's unfavourable view on near-term prospects for the UK
    non-standard credit markets.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Financial Institutions and
Covered Bond issuers have a best-case rating upgrade scenario
(defined as the 99th percentile of rating transitions, measured in
a positive direction) of three notches over a three-year rating
horizon; and a worst-case rating downgrade scenario (defined as the
99th percentile of rating transitions, measured in a negative
direction) of four notches over three years. The complete span of
best- and worst-case scenario credit ratings for all rating
categories ranges from 'AAA' to 'D'. Best- and worst-case scenario
credit ratings are based on historical performance.


RUBIX GROUP: S&P Puts 'B-' ICR on Watch Positive on Proposed IPO
----------------------------------------------------------------
S&P Global Ratings placing all of its ratings on Rubix Group
Holdings Ltd. (Rubix), including the 'B-' issuer rating and the
'B-' issue rating on the senior secured debt, on CreditWatch with
positive implications.

The CreditWatch placement represents the potential to upgrade Rubix
by up to two notches if the IPO proceeds are used to sustainably
reduce leverage and depends on the group's financial policy after
the IPO.

If Rubix successfully completes its IPO, the company is likely to
have sufficient proceeds to reduce gross debt levels significantly.
Rubix has announced its expected intention to float on the London
Stock Exchange. S&P said, "We expect the transaction to close in
December 2021. The company currently has around EUR1.8 billion of
reported debt outstanding, including its first- and second-lien
term loans, its revolving credit facility, its COVID-19-related
loans in France and Spain, and its preference shares, as well as
other short-term debt. We anticipate that the shareholder loans,
currently expected to be around EUR257 million by the end of 2021,
will be paid down through the subscription of shares by financial
sponsor Advent." The reduction in debt would help reduce the
company's interest burden.

Rubix's financial policy and the sponsor's control remain important
when considering whether it can sustain improving credit metrics.
S&P would only raise the rating if the company reduced debt
sufficiently to cut leverage sustainably from the current forecast
of around 9x-10x in 2021. This is subject to the financial policy
expected after the IPO, as well as the financial sponsor's level of
ownership and ability to exert control over Rubix's financial
direction.

CreditWatch

S&P plans to resolve the CreditWatch placement when the transaction
closes, which is expected to happen in December 2021. The
CreditWatch placement represents the potential to upgrade Rubix by
up to two notches if the IPO proceeds are used to reduce leverage
sustainably and depends on the group's financial policy after the
IPO.



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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-
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Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

Copyright 2021.  All rights reserved.  ISSN 1529-2754.

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