/raid1/www/Hosts/bankrupt/TCREUR_Public/211123.mbx        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, November 23, 2021, Vol. 22, No. 228

                           Headlines



C Z E C H   R E P U B L I C

CSA: Posts CZK105-Mil. Loss in First Nine Months of 2021


F R A N C E

VERALLIA SA: Moody's Upgrades CFR to Ba1, Outlook Remains Stable


G E R M A N Y

WIRECARD: EY Files Criminal Complaint Over Publication of Report


I R E L A N D

BARINGS EURO 2020-1: Moody's Assigns B3 Rating to Class F-R Notes
BARINGS EURO 2020-1: S&P Assigns B- (sf) Rating to Class F-R Notes
BRIDGEPOINT CLO 3: Moody's Assigns (P)B3 Rating to EUR12MM F Notes
HARVEST CLO XXV: S&P Assigns Prelim B- (sf) Rating to F-R Notes
PALMER SQUARE 2021-2: Fitch Rates Class F Tranche Final 'BB+'

PALMER SQUARE 2021-2: Moody's Assigns B1 Rating to EUR5MM F Notes
PALMER SQUARE 2022-1: Moody's Assigns (P)B3 Rating to Cl. F Notes
STARZ MORTGAGE 2021-1: S&P Assigns BB (sf) Rating to Cl. E Notes


I T A L Y

PAGANINI BIDCO: S&P Assigns 'B' ICR, Outlook Positive
TELECOM ITALIA: S&P Downgrades LT Rating to 'BB', Outlook Stable


N E T H E R L A N D S

SCHOELLER PACKAGING: Fitch Affirms 'B-' LT IDR, Outlook Stable


S P A I N

CODERE LUXEMBOURG 2: Moody's Assigns 'Caa3' CFR, Outlook Stable


U N I T E D   K I N G D O M

BULB ENERGY: To Be Placed Into "Special Administration"
CONSORT HEALTHCARE: Moody's Cuts Rating on GBP93.3MM Bonds to Ba2
PEOPLE'S FIBRE: Dispute with Investors Prompt Administration
PIERPONT BTL 2021-1: Moody's Gives Ba1 Rating to GBP6.5MM X1 Notes
PIERPONT BTL 2021-1: S&P Assigns B- (sf) Rating to X1-Dfrd Notes

PURE LEGAL: Lenders Likely to Receive GBP6.4MM of Money Owed
ROBIN HOOD: Collapse to Delay City Council's Signing of Accounts

                           - - - - -


===========================
C Z E C H   R E P U B L I C
===========================

CSA: Posts CZK105-Mil. Loss in First Nine Months of 2021
--------------------------------------------------------
Jakov Fabinger at Simple Flying reports that CSA, the Czech flag
carrier, has lost CZK105 million (US$4.6 million) in the first nine
months of the year.

However, it is making sufficient progress in paying off its debts,
and so it will remain in the process of business restructuring and
will not be declared bankrupt, Simple Flying discloses.

The insolvency administrator of CSA announced that he was satisfied
with the financial state of the Czech flag carrier in a report seen
by Simple Flying, Simple Flying relates.

CSA will remain in the process of business restructuring and will
not enter bankruptcy, Simple Flying states.  This is because it
generated sufficient revenue so far this year to pay off its
liabilities in full and in time, Simple Flying notes.

The Czech flag carrier generated sales revenue amounting to CZK522
million (US$23.2 million) between January and September 2021,
Simple Flying discloses.

Furthermore, the airline bolstered its liquidity in the same time
period by selling what the report calls "surplus assets", Simple
Flying relays.  Most notably, CSA sold its emissions permits in
what was the most lucrative surplus asset sale of this time period,
according to Simple Flying.

As a result, the insolvency administrator expressed the view that
there were no grounds on which to turn the business restructuring
into bankruptcy by closing down the business, Simple Flying states.
This means that CSA will continue to carry passengers, at least in
the short term, Simple Flying notes.

Despite the good news about escaping bankruptcy, the financial
standing of CSA remains poor, and this remains a cause for concern
regarding its future, Simple Flying says.

CSA is in the process of business restructuring led by INSKOL, a
Czech public trading company whose scope of business is to perform
the duties of the insolvency administrator in accordance with
national law, according to Simple Flying.

The net profit generated between January and September 2021 remains
a negative figure: the total loss recorded during these nine months
was CZK112.8 million (US$5.5 million), Simple Flying discloses.

CSA was able to settle its receivables as scheduled, despite the
negative financial result at the end of the year, Simple Flying.
recounts.  The airline has also canceled its Airbus orders, Simple
Flying recounts.  Still, further problems for the airline remain
ahead, Simple Flying states.

The solvency administrator did not conclusively state the level of
support among CSA's creditors for its ongoing proceedings at the
airline, according to Simple Flying.  his is because the
reorganization plan has still not been submitted, Simple Flying
states.




===========
F R A N C E
===========

VERALLIA SA: Moody's Upgrades CFR to Ba1, Outlook Remains Stable
----------------------------------------------------------------
Moody's Investors Service has upgraded to Ba1 from Ba2 the
corporate family rating of French glass packaging producer Verallia
S.A. The outlook on the rating remains stable.

"The upgrade to Ba1 reflects Verallia's solid operating performance
in 2021, exceeding our previous expectations, and our view that the
company will continue to grow its earnings and reduce leverage
owing to the recovery of demand for premium spirits and wines,
price increases, new capacity additions and targeted productivity
improvements, despite high input cost inflation and a weak harvest
in France," says Donatella Maso, a Moody's Vice President -- Senior
Analyst and lead analyst for Verallia.

"The upgrade also reflects the corporate governance considerations
associated with Verallia's decision to pursue a more conservative
financial policy, as the company has recently tightened its medium
term net leverage trajectory to below 2x from between 2x to 3x,"
adds Ms Maso. Financial strategy and risk management is a
governance consideration under Moody's General Principles for
Assessing Environmental, Social and Governance Risk Methodology for
assessing ESG risks.

RATINGS RATIONALE

The rating upgrade to Ba1 from Ba2 reflects Verallia's solid
operating performance YTD September 2021, which exceeded Moody's
previous expectations. Verallia's revenues increased by 3.4%
year-on-year supported by growth in volumes and positive price/mix
contribution, while its EBITDA continued to benefit from lower cash
production costs under the company's performance action plan in
addition to the improved top line, and increased by 11% to EUR528
million from EUR474 million year-over-year on a company's adjusted
basis. As a result, Verallia was able to reduce its Moody's
adjusted leverage to 3.2x LTM September 2021 from 3.5x in 2020.

Despite the out-of home consumption of alcoholic beverages is
gradually recovering, business conditions remain challenging in the
near term due to the high input cost inflation and partly to the
weak harvest in France, Verallia's most important market. However,
Moody's believes that Verallia will be able to mitigate these risks
by negotiating price increases in an industry experiencing tight
supply, benefitting from an advanced hedge of its energy needs and
its track record of cost savings, and increasing demand for Italian
and Spanish wines.

The rating agency expects Verallia to continue to grow its earnings
and to slowly deleverage on a gross debt basis to around 3.0x by
2022. While the rating remains supported by Verallia's cash
generation capacity, the absolute amount of free cash flow will be
lower than the c. EUR300 million posted in 2020, due to higher
capex for the construction of three new furnaces over the next
three years, two in Brazil and one in Italy, the investments
required to meet its CO2 emissions reduction targets, and
increasing cash dividends. Free cash flow in 2021-2022 will be
impaired further by working capital absorption to rebuild inventory
levels and the cash costs related to the completion of the
transformation plan in France.

The upgrade to Ba1 also reflects the company's decision to pursue a
more conservative medium-term net leverage trajectory of below
2.0x, as announced by the company on October 7, 2021 [1].

The tightening of the net leverage trajectory led the rating agency
to change its assessment of the company's Financial Strategy and
Risk Management to 2 from 3 and lower the overall exposure to
governance risks (Issuer Profile Score or "IPS") to neutral-to-low
(G-2) from moderately negative (G-3). However, Verallia's ESG
Credit Impact Score remains moderately negative (CIS-3) to reflect
limited credit impact to date, but the potential for environmental
risk factors to have an effect on the company's credit quality over
time. Verallia is highly exposed to tightening regulations for
carbon emissions owing to its intensive use of energy for the
manufacturing of glass containers. This consideration weighs on its
Issuer Profile Score for environmental risks, which Moody's has
assessed at E-4. At the same time, Moody's has assessed that
Verallia has a moderately negative exposure (S-3) to social risks.

Verallia's Ba1 rating continues to be supported by the company's
scale and position as the third largest glass container
manufacturer globally and the largest in Europe in a relatively
consolidated industry; its long-standing customer relationships and
its track record of operating as a high-quality and reliable
supplier; as well as its high profitability, owing to the lack of
material customer concentration, its ability to pass on volatile
input costs, although with some lags, and its track record in
achieving targeted operational improvements.

The Ba1 rating remains constrained by Verallia's exposure to
low-growth end markets with a degree of pricing pressure, partly
mitigated by the company's focus on the higher-margin
wine/sparkling wine and spirits segments, which are nevertheless
more susceptible to economic cycles; the limited substrate
diversity; the risk of at least temporary margin compression should
input cost inflation not be managed carefully; and its exposure to
currency and political headwinds because of its presence in some
emerging markets such as Latin America (representing 10% of
revenues) and Russia.

LIQUIDITY

Verallia's liquidity is good. It is supported by EUR580 million of
cash at the end of September 2021, the company's solid free cash
flow generation in excess of EUR100 million p.a. from 2022 onwards
and a EUR500 million revolving credit facility (RCF) due in 2024.
The RCF provides a backup for the EUR400 million commercial paper
programme, of which EUR150 million was outstanding as of September
30, 2021. Excluding the commercial paper programme, which is
short-term in nature, the next largest debt maturity is in 2024
when the c. EUR500 million term loan matures.

The loans have a net leverage covenant of 5.0x, which is tested
semi-annually, under which Moody's expects the company to retain
sufficient headroom. The company reported a net leverage of 1.8x at
the end of September 2021.

The company has also access to EUR450 million of factoring
facilities, of which around EUR350 million was drawn as of
September 2021.

RATIONALE FOR STABLE OUTLOOK

The stable outlook on the rating reflects Moody's expectations that
Verallia will be able to maintain its solid operating performance,
high profitability, a gross leverage below 3.5x and continue to
generate positive FCF on a sustained basis.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING

Upward pressure on the rating could materialise if the company's
operating performance remains strong while it develops a track
record operating under its stated financial policies, including a
net leverage ratio (as defined by the company) below 2.0x, and
below 2.75x (on a gross debt, Moody's adjusted basis); its EBITDA
margin remains around 25%; and (3) its free cash flow generation
(after interest, capex and dividends) remains healthy and
consistently positive.

Negative pressure on the rating could develop if Verallia's
operating performance deteriorates such that its Moody's-adjusted
debt/EBITDA increases above 3.5x on a sustainable basis, its free
cash flow weakens, or its liquidity significantly deteriorates. The
rating could also come under negative pressure in the event of a
more aggressive financial policy, including material debt funded
acquisitions or more shareholder-friendly actions.

LIST OF AFFECTED RATINGS

Upgrades:

Issuer: Verallia S.A.

LT Corporate Family Rating, Upgraded to Ba1 from Ba2

Outlook Actions:

Issuer: Verallia S.A.

Outlook, Remains Stable

PRINCIPAL METHODOLOGY

The principal methodology used in this rating was Packaging
Manufacturers: Metal, Glass and Plastic Containers Methodology
published in September 2020.

COMPANY PROFILE

Headquartered in France, Verallia is a global leading producer of
glass containers for the food and beverage industry. Verallia
operates 32 manufacturing plants, with 57 furnaces and 13 product
development centers in 11 countries, employing around 10,000
people. For the last twelve ending September 2021, Verallia
generated revenues of EUR2.6 billion and EBITDA of EUR684 million
(as adjusted by Moody's).

The company is listed on Euronext Paris since October 4, 2019. The
largest shareholder is BW GESTAO DE INVESTIMENTOS LTDA (BWGI) with
a 26.6% stake, while free float is around 58%.



=============
G E R M A N Y
=============

WIRECARD: EY Files Criminal Complaint Over Publication of Report
----------------------------------------------------------------
Olaf Storbeck at The Financial Times reports that EY has filed a
criminal complaint over a German newspaper's publication of a
classified parliamentary report into its work for disgraced
payments company Wirecard.

The criminal complaint was submitted on Nov. 22 to Munich criminal
prosecutors, the Big Four firm told the FT.  Prosecutors confirmed
they had received the complaint but declined to comment further,
the FT notes.

The highly critical report was written by Martin Wambach, a partner
at accounting firm Rodl & Partner, on behalf of the parliamentary
inquiry committee into the Wirecard scandal, the FT discloses.

According to the FT, it highlighted serious shortcomings in EY's
auditing work, finding that the firm failed to spot indicators of
fraud, did not fully implement professional guidelines and, on key
questions, relied on verbal assurances from executives.  The report
cited more than 150 internal EY documents that were submitted to
the committee but were deemed classified under German law, the FT
notes.

A lawsuit from MPs who had asked the Federal High Court of Justice
to allow the publication of an unredacted version of the report was
dismissed in August, the FT recounts.  An appeal against that
decision is still pending, the FT states.

On Nov. 11, Germany's financial daily Handelsblatt published the
full 168-page document on its website, the FT relays.  It argued
that the report, which is stamped "Deutscher Bundestag — Geheim",
was paid for by taxpayers and its content was of high public
interest, according to the FT.

In a statement on Nov. 22, the Big Four firm, as cited by the FT,
said: "From EY's point of view, handing over of the report [to
Handelsblatt] constitutes a violation of the legal process,
violates the highest court's authority and creates a fait
accompli."

The firm argued that the rights of employees who were mentioned in
the report, and whose names were not redacted by Handelsblatt, were
violated, the FT discloses.  It said moreover, the publication of
the report unduly exposed EY's business secrets, the FT relates.

A person close to EY told the FT that Handelsblatt's publication of
the full document was "a completely different order of magnitude".

EY said its criminal complaint was directed against the "unknown"
people who leaked the document and did not target Handelsblatt
journalists, the FT notes.




=============
I R E L A N D
=============

BARINGS EURO 2020-1: Moody's Assigns B3 Rating to Class F-R Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to refinancing notes issued by Barings
Euro CLO 2020-1 Designated Activity Company (the "Issuer"):

EUR310,000,000 Class A-R Senior Secured Floating Rate Notes due
2034, Definitive Rating Assigned Aaa (sf)

EUR50,000,000 Class B-R Senior Secured Floating Rate Notes due
2034, Definitive Rating Assigned Aa2 (sf)

EUR31,250,000 Class C-R Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned A2 (sf)

EUR35,000,000 Class D-R Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned Baa3 (sf)

EUR23,750,000 Class E-R Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned Ba3 (sf)

EUR15,500,000 Class F-R Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

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

As part of this reset, the Issuer has increased the target par
amount by EUR50 Million to EUR500 million. In addition, the Issuer
has amended the base matrix and modifiers that Moody's has taken
into account for the assignment of the definitive ratings.

The Issuer is a managed cash flow CLO. At least 92.5% of the
portfolio must consist of secured senior loans or senior secured
bonds and up to 7.5% of the portfolio may consist of unsecured
senior loans, second-lien loans, high yield bonds and mezzanine
loans. The underlying portfolio is 90% ramped as of the closing
date.

Barings (U.K.) Limited ("Barings") will continue to manage the CLO.
It will direct the selection, acquisition and disposition of
collateral on behalf of the Issuer and may engage in trading
activity, including discretionary trading, during the transaction's
four and a half year reinvestment period. Thereafter, subject to
certain restrictions, purchases are permitted using principal
proceeds from unscheduled principal payments and proceeds from
sales of credit risk obligations and credit improved obligations.

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

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in December 2020.

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

Target Par Amount: EUR500.0m

Defaulted Par: EUR1,488,491 as of Sept 2021

Diversity Score: 48

Weighted Average Rating Factor (WARF): 3017

Weighted Average Spread (WAS): 3.65%

Weighted Average Coupon (WAC): 4.75%

Weighted Average Recovery Rate (WARR): 44.0%

Weighted Average Life (WAL): 8.5 years

BARINGS EURO 2020-1: S&P Assigns B- (sf) Rating to Class F-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned credit ratings to Barings Euro CLO
2020-1 DAC's class A-R to F-R European cash flow CLO notes. At
closing, the issuer also issued unrated subordinated notes.

The transaction is a reset of the existing Barings Euro CLO 2020-1
DAC transaction, which closed in November 2020.

The issuance proceeds of the refinancing notes will be used to
redeem the notes (class A, B-1, B-2, C-1, C-2, D, E, and F of the
original Barings Euro CLO 2020-1 DAC), and pay fees and expenses
incurred in connection with the reset.

The reinvestment period, originally scheduled to last until October
2023, will be extended to April 2026. The covenanted maximum
weighted-average life will be 8.5 years from closing.

The ratings reflect our assessment of:

-- The diversified collateral pool, which consists primarily of
broadly syndicated speculative-grade senior-secured term loans and
bonds that are governed by collateral quality tests.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which is bankruptcy remote.

-- The transaction's counterparty risks, which are in line with
S&P's counterparty rating framework.

  Portfolio Benchmarks
                                                        CURRENT
  S&P weighted-average rating factor                   2,782.34
  Default rate dispersion                                664.35
  Weighted-average life (years)                            5.14
  Obligor diversity measure                              123.30
  Industry diversity measure                              19.99
  Regional diversity measure                               1.39

  Transaction Key Metrics
                                                        CURRENT
  Portfolio weighted-average rating
  derived from our CDO evaluator                              B
  'CCC' category rated assets (%)                          4.52
  Covenanted 'AAA' weighted-average recovery (%)          36.50
  Covenanted weighted-average spread (%)                   3.65
  Covenanted weighted-average coupon (%)                   4.75

The transaction allows the purchase of loss mitigation loans. Loss
mitigation loans allow the issuer to participate in potential new
financing initiatives by the borrower in default. This feature aims
to mitigate the risk of other market participants taking advantage
of CLO restrictions, which typically do not allow the CLO to
participate in a defaulted entity's new financing request, and
hence increase the chance of increased recovery for the CLO. While
the objective is positive, it can also lead to par erosion, as
additional funds will be placed with an entity that is under
distress or in default. This may cause greater volatility in our
ratings if the positive effect of such loans does not materialize.
In S&P's view, the presence of a bucket for loss mitigation loans,
the restrictions on the use of principal proceeds to purchase such
assets, and the limitations in reclassifying proceeds received from
such assets from principal to interest help to mitigate the risk.

Loss mitigation loan mechanics

Under the transaction documents, the issuer can purchase loss
mitigation loans, which are assets of an existing collateral
obligation held by the issuer offered in connection with
bankruptcy, workout, or restructuring of such obligation, to
improve the recovery value of such related collateral obligation.

The purchase of loss mitigation loans is not subject to the
reinvestment criteria or the eligibility criteria. Other than
qualifying loss mitigation loans--which receive a defaulted
treatment-it receives no credit in either the principal balance or
par coverage test numerator definition, and is limited to 5% of the
target par amount. The cumulative exposure to loss mitigation loans
is limited to 10% of the target par amount.

The issuer may purchase loss mitigation loans using either interest
proceeds, principal proceeds, or amounts standing to the credit of
the supplemental reserve account. The use of interest proceeds to
purchase loss mitigation loans are subject to (1) all the interest
and par coverage tests passing following the purchase, and (2) the
manager determining there are sufficient interest proceeds to pay
interest on all the rated notes on the upcoming payment date. The
usage of principal proceeds is subject to (1) passing par coverage
tests, (2) the manager having built sufficient excess par in the
transaction so that the principal collateral amount is equal to or
exceeds the portfolio's reinvestment target par balance after the
reinvestment, and (3) the class F par value coverage ratio is equal
to or greater than 103.91%.

To protect the transaction from par erosion, any distributions
received from loss mitigation loans that are purchased with the use
of principal proceeds will form part of the issuer's principal
account proceeds and cannot be recharacterized as interest unless
(1) the principal collateral amount is equal to or exceeds the
portfolio's reinvestment target par balance, and (2) until the
amounts received from the loss mitigation loan, plus the recoveries
of the related defaulted obligation (or credit risk obligation),
equals the sum of the outstanding principal balance of the
defaulted obligation (or credit risk obligation) and the principal
proceeds used to purchase the loss mitigation loan.

Under the transaction documents, the rated notes will pay quarterly
interest unless a frequency switch event occurs. Following this,
the notes will switch to semiannual payments. The portfolio's
reinvestment period will end approximately four years after
closing.

The portfolio is well-diversified, primarily comprising broadly
syndicated speculative-grade senior-secured term loans and
senior-secured bonds. Therefore, S&P has conducted our credit and
cash flow analysis by applying its criteria for corporate cash flow
CDOs.

S&P said, "In our cash flow analysis, we used the EUR500 million
target par amount, the covenanted weighted-average spread (3.65%),
the reference weighted-average coupon (4.75%), and the covenanted
'AAA' weighted-average recovery rate (36.50%) as indicated by the
collateral manager. We applied various cash flow stress scenarios,
using four different default patterns, in conjunction with
different interest rate stress scenarios for each liability rating
category.

"Under our structured finance sovereign risk criteria, we consider
that the transaction's exposure to country risk is sufficiently
mitigated at the assigned ratings."

Until the end of the reinvestment period on April 21, 2026, the
collateral manager may substitute assets in the portfolio for so
long as S&P's CDO Monitor test is maintained or improved in
relation to the initial ratings on the notes. This test looks at
the total amount of losses that the transaction can sustain as
established by the initial cash flows for each rating, and it
compares that with the current portfolio's default potential plus
par losses to date. As a result, until the end of the reinvestment
period, the collateral manager may through trading deteriorate the
transaction's current risk profile, as long as the initial ratings
are maintained.

The transaction's documented counterparty replacement and remedy
mechanisms adequately mitigate its exposure to counterparty risk
under our current counterparty criteria.

The transaction's legal structure and framework is bankruptcy
remote, in line with its legal criteria.

S&P said, "Following our analysis of the credit, cash flow,
counterparty, operational, and legal risks, we believe our ratings
are commensurate with the available credit enhancement for the
class A-R to E-R notes. Our credit and cash flow analysis indicates
that the available credit enhancement could withstand stresses
commensurate with the same or higher rating levels than those we
have assigned. However, as the CLO will be in its reinvestment
phase starting from closing, during which the transaction's credit
risk profile could deteriorate, we have capped our ratings assigned
to the notes.

"Taking the above factors into account and following our analysis
of the credit, cash flow, counterparty, operational, and legal
risks, we believe that our ratings are commensurate with the
available credit enhancement for all of the rated classes of
notes.

"In addition to our standard analysis, to provide an indication of
how rising pressures among speculative-grade corporates could
affect our ratings on European CLO transactions, we have also
included the sensitivity of the ratings on the class A-R to E-R
notes to five of the 10 hypothetical scenarios we looked at in our
publication.

"As our ratings analysis makes additional considerations before
assigning ratings in the 'CCC' category, and we would assign a 'B-'
rating if the criteria for assigning a 'CCC' category rating are
not met, we have not included the above scenario analysis results
for the class F-R notes."

Environmental, social, and governance (ESG) credit factors

S&P said, "We regard the exposure to ESG credit factors in the
transaction as being broadly in line with our benchmark for the
sector. Primarily due to the diversity of the assets within CLOs,
the exposure to environmental credit factors is viewed as below
average, social credit factors are below average, and governance
credit factors are average. For this transaction, the documents
prohibit assets from being related to the following industries:
production or marketing of controversial weapons, tobacco or
tobacco-related products, nuclear weapons, thermal coal production,
speculative extraction of oil and gas, pornography or prostitution,
or opioid manufacturing and distribution. Accordingly, since the
exclusion of assets from these industries does not result in
material differences between the transaction and our ESG benchmark
for the sector, no specific adjustments have been made in our
rating analysis to account for any ESG-related risks or
opportunities."

  Assigned Ratings

  Ratings List

  CLASS    RATING     AMOUNT     INTEREST RATE (%)    CREDIT      

                    (MIL. EUR)                    ENHANCEMENT (%)
  A-R      AAA (sf)   310.00      3mE + 0.98        38.00

  B-R      AA (sf)     50.00      3mE + 1.75        28.00

  C-R      A (sf)      31.25      3mE + 2.30        21.75

  D-R      BBB- (sf)   35.00      3mE + 3.40        14.75

  E-R      BB- (sf)    23.75      3mE + 6.17        10.00

  F-R      B- (sf)     15.50      3mE + 8.78         6.90

  Sub      NR          38.80      N/A                 N/A

  NR--Not rated.
  N/A--Not applicable.
  3mE--Three-month Euro Interbank Offered Rate.


BRIDGEPOINT CLO 3: Moody's Assigns (P)B3 Rating to EUR12MM F Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following provisional ratings to notes to be issued by Bridgepoint
CLO 3 Designated Activity Company (the "Issuer"):

EUR248,000,000 Class A Senior Secured Floating Rate Notes due
2036, Assigned (P)Aaa (sf)

EUR42,000,000 Class B Senior Secured Floating Rate Notes due 2036,
Assigned (P)Aa2 (sf)

EUR24,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2036, Assigned (P)A2 (sf)

EUR28,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2036, Assigned (P)Baa3 (sf)

EUR19,200,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2036, Assigned (P)Ba3 (sf)

EUR12,000,000 Class F Senior Secured Deferrable Floating Rate
Notes due 2036, Assigned (P)B3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow CLO. At least 90% of the
portfolio must consist of senior secured obligations and up to 10%
of the portfolio may consist of senior unsecured obligations,
second-lien loans, mezzanine obligations and high yield bonds. The
portfolio is expected to be 50% ramped up as of the closing date
and to comprise of predominantly corporate loans to obligors
domiciled in Western Europe. The remainder of the portfolio will be
acquired during the six month ramp-up period in compliance with the
portfolio guidelines.

Bridgepoint Credit Management Limited ("Bridgepoint") will manage
the CLO. It will direct the selection, acquisition and disposition
of collateral on behalf of the Issuer and may engage in trading
activity, including discretionary trading, during the transaction's
four and a half year reinvestment period. Thereafter, subject to
certain restrictions, purchases are permitted using principal
proceeds from unscheduled principal payments and proceeds from
sales of credit risk obligations or credit improved obligations.

In addition to the six classes of notes rated by Moody's, the
Issuer will issue EUR34,700,000 Subordinated Notes due 2036 which
will not be rated.

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

Methodology underlying the rating action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in December 2020.

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

Par Amount: EUR400,000,000

Diversity Score: 46

Weighted Average Rating Factor (WARF): 2950

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 4.20%

Weighted Average Recovery Rate (WARR): 43.75%

Weighted Average Life (WAL): 8.75 years (*)

HARVEST CLO XXV: S&P Assigns Prelim B- (sf) Rating to F-R Notes
---------------------------------------------------------------
S&P Global Ratings assigned its preliminary credit ratings to
Harvest CLO XXV DAC's class A-R, B-1-R, B-2-R, C-R, D-R, E-R, and
F-R notes. At closing, the issuer will not issue additional unrated
subordinated notes in addition to the EUR65.64 million of existing
unrated subordinated notes.

The transaction is a reset of an existing transaction, which closed
in November 2020.

The ratings reflect S&P's assessment of:

-- The diversified collateral pool, which primarily comprises
broadly syndicated speculative-grade senior-secured term loans and
bonds that are governed by collateral quality tests.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which S&P expects to be
bankruptcy remote.

-- The transaction's counterparty risks, which S&P expects to be
line with its counterparty rating framework.

  Portfolio Benchmarks
                                                       CURRENT
  S&P weighted-average rating factor                  2,896.47
  Default rate dispersion                               394.97
  Weighted-average life (years)                           5.29
  Obligor diversity measure                             133.84
  Industry diversity measure                             19.55
  Regional diversity measure                              1.38

  Transaction Key Metrics
                                                       CURRENT
  Total par amount (mil. EUR)                              475
  Defaulted assets (mil. EUR)                                0
  Number of performing obligors                            175
  Portfolio weighted-average rating
   derived from S&P's CDO evaluator                        'B'
  'CCC' category rated assets (%)                         1.68
  'AAA' weighted-average recovery (%)                    35.24
  Covenanted weighted-average spread (%)                  3.80
  Covenanted weighted-average coupon (%)                  4.00

Under the transaction documents, the refinanced notes will pay
quarterly interest unless there is a frequency switch event.

The manager may purchase loss mitigation obligations in connection
with the default of an existing asset to enhance the global
recovery on the assets held by that obligor. The manager may also
exchange defaulted obligations for other defaulted obligations from
a different obligor with a better likelihood of recovery.

S&P siad, "Our preliminary ratings reflect our assessment of the
collateral portfolio's credit quality. Therefore, we have conducted
our credit and cash flow analysis by applying our criteria for
corporate cash flow collateralized debt obligations.

"In our cash flow analysis, we used the EUR475 million target par
amount, a weighted-average spread of 3.80%, a weighted-average
coupon of 4.00%, and the actual weighted-average recovery rates for
all rating categories calculated in line with our CLO criteria

"We applied various cash flow stress scenarios, using four
different default patterns, in conjunction with different interest
rate stress scenarios for each liability rating category.

"Following our analysis of the reset notes, we believe our
preliminary ratings are commensurate with the available credit
enhancement for the class A-R to E-R notes. Our credit and cash
flow analysis also indicates that the available credit enhancement
for the class B-1-R, B-2-R, and C-R notes could withstand stresses
commensurate with higher ratings than those we have assigned.
However, as the CLO will be in its reinvestment phase, during which
the transaction's credit risk profile could deteriorate, we have
capped our assigned preliminary ratings on the notes.

"For the class F-R notes, our credit and cash flow analysis
indicates that the available credit enhancement could withstand
stresses that are commensurate with a 'CCC+' rating. However
following the application of our 'CCC' rating criteria, we have
assigned a preliminary 'B-' rating to this class of notes." The one
notch rating uplift (to 'B-') from the model generated results (of
'CCC'), reflects several key factors, including:

-- The available credit enhancement for this class of notes is in
the same range as other CLOs that we rate, and that have recently
been issued in Europe.

-- The portfolio's average credit quality is similar to other
recent CLOs.

-- S&P's model generated BDR at the 'B-' rating level of 27.18%
(for a portfolio with a weighted-average life of 5.29 years),
versus if it was to consider a long-term sustainable default rate
of 3.1% for 5.29 years, which would result in a target default rate
of 16.399%.

-- For S&P to assign a rating in the 'CCC' category, it also
assessed (i) whether the tranche is vulnerable to non-payments in
the near future, (ii) if there is a one in two chance for this note
to default, and (iii) if it envisions this tranche to default in
the next 12-18 months.

-- Following this analysis, S&P considers that the available
credit enhancement for the class F-R notes is commensurate with the
'B- (sf)' rating assigned.

Bank of New York Mellon, London Branch is the bank account provider
and custodian. At closing, S&P expects the transaction's documented
counterparty replacement and remedy mechanisms to be in line with
its current counterparty criteria.

S&P said, "Under our structured finance sovereign risk criteria, we
consider that the transaction's exposure to country risk is
sufficiently mitigated at the assigned preliminary ratings.

"At closing, we expect the transaction's legal structure to be
bankruptcy remote, in line with our legal criteria.

"Following our analysis of the credit, cash flow, counterparty,
operational, and legal risks, we believe our preliminary ratings
are commensurate with the available credit enhancement for each
class of notes."

Environmental, social, and governance (ESG) factors

S&P said, "We regard the exposure to ESG credit factors in the
transaction as being broadly in line with our benchmark for the
sector. Primarily due to the diversity of the assets within CLOs,
the exposure to environmental credit factors is viewed as below
average, social credit factors are below average, and governance
credit factors are average. For this transaction, the documents
prohibit assets from being related to the following industries
(non-exhaustive list): the production or trade of illegal drugs or
narcotics, the production and/or sale of controversial weapons,
thermal coal production, non-sustainable palm oil production, tar
sands extraction, and pornography. Accordingly, since the exclusion
of assets from these industries does not result in material
differences between the transaction and our ESG benchmark for the
sector, no specific adjustments have been made in our rating
analysis to account for any ESG-related risks or opportunities."

  Ratings List

  CLASS    PRELIM.     PRELIM.     INTEREST RATE (%)    CREDIT
           RATING      AMOUNT                         ENHANCEMENT  
                  
                     (MIL. EUR)                           (%)

  A-R      AAA (sf)    290.94    Three-month EURIBOR     38.75
                                 plus 0.95%

  B-1-R    AA (sf)      27.55    Three-month EURIBOR     29.50
                                 plus 1.80%
   
  B-2-R    AA (sf)      16.39    2.05%                   29.50

  C-R      A (sf)       34.44    Three-month EURIBOR     22.25
                                 plus 2.40%

  D-R      BBB (sf)     34.44    Three-month EURIBOR     15.00
                                 plus 3.45%

  E-R      BB- (sf)     26.13    Three-month EURIBOR      9.50
                                 plus 6.32%

  F-R      B- (sf)      13.06    Three-month EURIBOR      6.75
                                 plus 8.95%

  Subordinated  NR      65.64    N/A                       N/A

  NR--Not rated.
  N/A--Not applicable.
  3mE--Three-month Euro Interbank Offered Rate.


PALMER SQUARE 2021-2: Fitch Rates Class F Tranche Final 'BB+'
-------------------------------------------------------------
Fitch Ratings has assigned Palmer Square European Loan Funding
2021-2 DAC final ratings.

    DEBT                                 RATING
    ----                                 ------
Palmer Square European Loan Funding 2021-2 DAC

A XS2397057402                    LT AAAsf    New Rating
B XS2397058475                    LT AA+sf    New Rating
C XS2397058129                    LT A+sf     New Rating
D XS2397058632                    LT BBB+sf   New Rating
E XS2397058988                    LT BBB-sf   New Rating
F XS2397059283                    LT BB+sf    New Rating
Subordinated Notes XS2397059366   LT NRsf     New Rating

TRANSACTION SUMMARY

Palmer Square European Loan Funding 2021-2 DAC is an arbitrage cash
flow collateralised loan obligation (CLO) that is being serviced by
Palmer Square Europe Capital Management LLC (Palmer Square). Net
proceeds from the issued notes were used to purchase a static pool
of primarily secured senior loans and bonds, totaling about
EUR500million.

KEY RATING DRIVERS

'B' Portfolio Credit Quality (Neutral): Fitch places the average
credit quality of obligors in the 'B' category. The Fitch-weighted
average rating factor (WARF) of the current portfolio is 23.3.

High Recovery Expectations (Positive): Senior secured obligations
make up 100% of the portfolio. 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 current portfolio is 65.8%.

Diversified Portfolio Composition (Positive): The three-largest
industries comprise 28.6% of the portfolio balance, the top 10
obligors represent 9.3% of the portfolio balance and no single
obligor represents more than 1.5% of the portfolio.

Static Portfolio (Positive): The transaction does not have a
reinvestment period and discretionary sales are not permitted.
Fitch's analysis is based on both the current portfolio and a
stressed portfolio by applying a one-notch downgrade to all
obligors with a Negative Outlook (floored at 'CCC').

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 lead to downgrades of up to five notches for
    the rated notes.

-- Downgrades may occur if the build-up of the notes' credit
    enhancement following amortisation does not compensate for a
    larger loss 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 RDR across all ratings and a 25%
    increase in the RRR across all ratings would lead to upgrades
    of up to three notches for the rated notes, except for the
    class A notes, which are already at the highest rating on
    Fitch's scale and therefore cannot be upgraded.

-- Upgrades could occur in case of a sustained better-than
    initially expected portfolio credit quality and deal
    performance, and continued amortisation that leads to higher
    credit enhancement for the notes and excess spread available
    to cover losses in the remaining portfolio. Upgrades of sub
    investment grade tranches could be more limited and may occur
    after significant amortisation of the senior tranches and
    sustained stable portfolio performance.

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.

PALMER SQUARE 2021-2: Moody's Assigns B1 Rating to EUR5MM F Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to the Notes issued by Palmer Square
European Loan Funding 2021-2 Designated Activity Company (the
"Issuer"):

EUR340,000,000 Class A Senior Secured Floating Rate Notes due
2031, Assigned Aaa (sf)

EUR60,000,000 Class B Senior Secured Floating Rate Notes due 2031,
Assigned Aa2 (sf)

EUR22,500,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned A2 (sf)

EUR25,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned Baa3 (sf)

EUR17,500,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned Ba2 (sf)

EUR5,000,000 Class F Senior Secured Deferrable Floating Rate Notes
due 2031, Assigned B1 (sf)

RATINGS RATIONALE

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

The Issuer is a static CLO. The issued notes will be collateralized
primarily by broadly syndicated senior secured corporate loans. The
portfolio will be fully ramped as of the closing date.

Palmer Square Europe Capital Management LLC (the "Servicer") may
engage is disposition of the assets on behalf of the Issuer during
the life of the transaction. Reinvestment is not permitted and all
sale and unscheduled principal proceeds received will be used to
amortize the notes in sequential order.

In addition, the Issuer will issue EUR32,600,000 of Subordinated
Notes due 2031 which are not rated.

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

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in December 2020.

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

Par Amount: EUR500,114,577.27

Diversity Score: 63

Weighted Average Rating Factor (WARF): 2727

Weighted Average Spread (WAS): 3.54% (actual spread vector of the
portfolio)

Weighted Average Coupon (WAC): 3.77% (actual spread vector of the
portfolio)

Weighted Average Recovery Rate (WARR): 46.16%

Weighted Average Life (WAL): 5.45 years (actual amortization vector
of the portfolio)

PALMER SQUARE 2022-1: Moody's Assigns (P)B3 Rating to Cl. F Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following provisional ratings to notes to be issued by Palmer
Square European CLO 2022-1 DAC (the "Issuer"):

EUR248,000,000 Class A Senior Secured Floating Rate Notes due
2035, Assigned (P)Aaa (sf)

EUR35,000,000 Class B-1 Senior Secured Floating Rate Notes due
2035, Assigned (P)Aa2 (sf)

EUR5,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2035,
Assigned (P)Aa2 (sf)

EUR26,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2035, Assigned (P)A2 (sf)

EUR27,200,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2035, Assigned (P)Baa3 (sf)

EUR20,400,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2035, Assigned (P)Ba3 (sf)

EUR10,800,000 Class F Senior Secured Deferrable Floating Rate
Notes due 2035, Assigned (P)B3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow CLO. At least 90% of the
portfolio must consist of senior secured obligations and up to 10%
of the portfolio may consist of senior unsecured obligations,
unsecured senior obligations, second-lien loans, mezzanine
obligations and high yield bonds. The portfolio is expected to be
between 95% to 100% ramped as of the closing date and to comprise
of predominantly corporate loans to obligors domiciled in Western
Europe. The remainder of the portfolio will be acquired during the
6 month ramp-up period in compliance with the portfolio
guidelines.

Palmer Square Europe Capital Management LLC ("Palmer Square") will
manage the CLO. It will direct the selection, acquisition and
disposition of collateral on behalf of the Issuer and may engage in
trading activity, including discretionary trading, during the
transaction's 4.6-year reinvestment period. Thereafter, subject to
certain restrictions, purchases are permitted using principal
proceeds from unscheduled principal payments and proceeds from
sales of credit risk obligations or credit improved obligation.

In addition to the seven classes of notes rated by Moody's, the
Issuer will issue EUR33,500,000 of Subordinated Notes which are not
rated.

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

Methodology underlying the rating action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in December 2020.

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

Par Amount: EUR400,000,000

Diversity Score: 50

Weighted Average Rating Factor (WARF): 2925

Weighted Average Spread (WAS): 3.50%

Weighted Average Coupon (WAC): 4.00%

Weighted Average Recovery Rate (WARR): 44.00%

Weighted Average Life (WAL): 8.5 years

STARZ MORTGAGE 2021-1: S&P Assigns BB (sf) Rating to Cl. E Notes
----------------------------------------------------------------
S&P Global Ratings assigned credit ratings to Starz Mortgage
Securities 2021-1 DAC's class A1, B1, C1, D1, E, and F British
pound sterling (GBP) notes and A2, B2, C2, and D2 euro (EUR) notes
under its European CMBS criteria. At closing, Starz Mortgage
Securities 2021-1 also issued unrated subordinated GBP notes.

Payments due on the notes will primarily be made from receipts from
the loan interests that correspond to the relevant currency of the
notes. The GBP notes are primarily backed by six loans and the EUR
notes are primarily backed by three loans. However, both GBP and
EUR receipts can be used to pay the other currencies note
liabilities, if they are available after the payment of their own
note liabilities. In S&P's analysis, it did not give credit to this
as this is subject to currency risk.

Starz Mortgage Capital originated these nine loans between 2018 and
2020. These loans backing this true sale transaction total £219.8
million and are secured by 17 properties located in the U.K.,
Netherlands, Ireland, and Spain.

Starz Mortgage Capital Ltd. and Starz ICAV (on behalf of Starz
European Loan Fund I), acquired and retained, an eligible
horizontal residual interest in the form of 100% of the
subordinated notes to satisfy EU and U.S. risk retention
requirements.

The current weighted-average loan-to-value (LTV) ratio of the loans
is 65.1%, with the individual LTV ratios ranging from 48.8% (the
Bakker loan) to 75.4% (the Node loan). FAH, the largest loan,
accounts for 17.4% of the total loan pool balance and is secured
against a portfolio of four properties within the social/affordable
housing sector in the U.K.

Of the nine loans, one loan, the Maxim loan (11.1% of the total
loan pool), has a two-year extension option until July 2024, with
the last maturing loan in April 2025. Seven (82.0% of the total
loan pool) of the nine loans are interest-only while the other two
loans feature an element of scheduled amortization.

S&P's ratings on the class A1/A2, B1/B2, C1/C2, and D1/D2 notes
address the issuer's ability to meet timely interest payments and
principal repayments no later than the legal final maturity in
November 2038. The ratings on the class E and F notes address the
ultimate payment of principal and interest by the legal final
maturity date. Should there be insufficient funds on any note
payment date to make timely interest payments on the class E and F
notes, the interest will be added to the note principal and will
accrue interest at the same rate as the respective class of notes.

S&P's ratings on the notes reflect its assessment of the underlying
loans' credit, cash flow, and legal characteristics, and an
analysis of the transaction's counterparty and operational risks.

  Ratings

  CLASS      RATING

  Offered notes

  A1/A2      AAA (sf)/AAA (sf)

  B1/B2      AA- (sf)/AA+ (sf)

  C1/C2      A (sf)/AA (sf)

  D1/D2      BBB- (sf)/A (sf)

  E          BB (sf)

  Non-offered notes

  F          B- (sf)

  Subordinated notes  NR

  NR--Not rated.




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

PAGANINI BIDCO: S&P Assigns 'B' ICR, Outlook Positive
-----------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to Italian higher education services group Paganini Bidco SpA and
its 'B' issue rating, with a '3'(55%) recovery rating, to the
company's floating rate notes.

The positive outlook reflects S&P's expectation that the company
will achieve substantial EBITDA growth, on the back of a growing
student base, such that S&P Global Ratings-adjusted leverage will
decline sustainably below 5.0x and free operating cash flow (FOCF)
to debt will exceed 10% in the next 12-18 months. An upgrade would
be contingent on clear commitment to maintain conservative credit
metrics within these thresholds over the long term.

The final ratings are in line with the preliminary ratings S&P
assigned in October.

On Oct. 28, CVC-owned Paganini Bidco SpA acquired the remaining 50%
of Multiversity s.r.l., the leading Italian online university
platform.

The acquisition was financed through EUR765 million of floating
rate notes, a EUR222 million bridge to cash facility, and a EUR100
million super senior revolving credit facility (RCF), which was
EUR39 million drawn at closing; CVC contributed EUR42 million of
equity.

CVC's buyout translates into S&P Global Ratings-adjusted leverage
above 6.0x in 2021, declining to 5.0x in 2022 on EBITDA growth. CVC
acquired the remaining 50% of Multiversity from the founder for a
cash consideration of about EUR800 million, financed through a
EUR42 million equity contribution and the issuance of EUR765
million of floating-rate notes. The notes were issued by the
acquisition vehicle Paganini, which will be later reverse-merged
into Multiversity. Paganini also issued a EUR222 million bridge to
cash facility that will be reimbursed as soon as the reverse merger
is concluded, using the cash at Multiversiy's intermediate holding
companies Wversity and MultiSpa--equal to EUR228 million. Following
the transaction, we expect Multiversity's S&P Global
Ratings-adjusted leverage to be about 6.0x in 2021, declining to
5.0x in 2022 on EBITDA growth driven by a solid increase in
enrolled students. S&P said, "Although we anticipate the company
will capitalize on its solid growth to deleverage further in the
medium term, we note that the group could potentially relever
within the debt documentation framework on the back of its private
equity ownership. Typically, based on our experience, private
equity ownership reflects a focus on maximizing shareholder
returns."

Good brand recognition, competitive pricing, and an established
network support Multiversity's leading position in its niche
market. Multiversity firmly holds the leading position in the niche
but fast-growing Italian online university segment, being more than
twice the size of the second largest player. Through its two
university brands--Pegaso and Mercatorum--as well as its ancillary
education services, Multiversity offers 25 bachelor's degrees, 11
master's degrees, and about a hundred other higher education
courses, at prices well below the average of other private
universities. Since its foundation in 2006, the group has built
strong brand recognition, thanks to significant marketing
investments as well as a physical network of about 100 exam venues
and about 3,000 e-learning center points (ECPs), which offer
proximity to students despite the virtual business model. ECPs are
third-party promotors that offer student orientation services for
Multiversity in exchange for a percentage of tuition fees. S&P
said, "We believe Multiversity's positioning also benefits from its
unique partnership with private and public institutions (such as
the Italian Chamber of Commerce) as well as from the internally
developed digital platform, where students access lessons, courses,
study materials, and exams. The digital business model exposes the
company to cyberattacks more than traditional universities, but we
understand the group has established a strong cybersecurity
framework and has not been affected to date from any cyber- related
issue."

A structural shift toward digitalization will increase the
penetration of online universities, while regulation limits
competition over the medium term. S&P said, "We expect online
universities in Italy--which currently account for less than 10% of
total enrolled students--will continue to experience strong growth
in the coming years, compared with the sluggish student base of
traditional universities. Online universities will benefit from the
structural trends toward digitalization of education, which the
COVID-19 pandemic has accelerated. We believe online universities
could also benefit from some Italian country-specific
characteristics, such as the territory's rural nature, with a
significant portion of population not living close to a university;
and the institutional push to increase the proportion of graduates,
which is one of the lowest among developed countries. Although
these trends will make the segment attractive to both existing
traditional universities and new players, the market has
significant regulatory barriers to entry, which we believe will
limit the number of new entrants in the medium term." This is
because online universities need to be officially recognized by the
Italian Ministry of Education through a specific license. Since
2003, the ministry granted only 11 online-university
licenses--including to Pegaso and Mercatorum--with no new entrants
since 2006, and it is not expected to grant any new permits until
at least 2024.

Low and flexible cost base supports Multiversity's above-average
profitability and cash flow. S&P said, "We expect Multiversity's
adjusted EBITDA margin will remain above 50%, on its digital and
easily scalable business model, characterized by the lack of costly
physical venues and limited personnel cost. We estimate the group's
cost base mostly comprises the contribution it pays to the ECPs
(about 12.5% of revenue) and marketing expenses (about 14.2%),
while educational personnel costs and research account for only
about 4.0% and rent and headquarters costs for about 7.5%. Of
importance, contributions paid to ECPs in exchange for their
orientation activity are calculated as a percentage of tuition fees
and, as such, are fully variable. Strong profitability and lack of
significant capital expenditure needs translate into high cash
conversion, with FOCF expected to remain above EUR80 million per
year in our forecast horizon through 2024. Given the strong cash
balance of EUR191 million at closing and lack of dividends and
acquisitions in management's base-case scenario, we expect
Multiversity's cash on balance will exceed EUR250 million by
December 2022 and EUR340 million by 2023."

Limited scale of operations and lack of geographic diversification
constrain the rating. With about 130,000 students in 2020,
Multiversity is the leading Italian online university, but it has a
market share of only 3.0%-4.0% in the broader university market,
including traditional universities. S&P said, "Despite the
segment's fast growth, we believe online teaching will remain a
niche in a largely fragmented market, as we expect online
penetration will likely stabilize in the long term, as virtual
platforms will not be able to fully replace traditional
universities. Our rating is also constrained by Multiversity's
geographical concentration, with 100% of revenue and EBITDA
generated in Italy, which make the company highly dependent on the
country's regulatory environment. Despite the broad product and
service offering, we also note that Pegaso accounts for about the
80% of the group's students and revenue, exposing the business to
some brand concentration, although we expect this to improve in the
medium term."

The positive outlook reflects S&P's expectation that the company
will achieve substantial EBITDA growth, on the back of a growing
student base, such that S&P Global Ratings-adjusted leverage will
decline sustainably below 5.0x and FOCF to debt will exceed 10% in
the next 12-18 months. An upgrade would be contingent on clear
commitment to maintain conservative credit metrics within these
thresholds over the long term.

S&P could upgrade the company if:

-- The reverse merger proceed as expected, with the company using
the cash available at MultiSpA and Wversity to repay the bridge to
cash facility.

-- Multiversity achieves substantial student growth with revenue
approaching EUR300 million by 2022, while maintaining an adjusted
EBITDA margin above 50% with solid cash conversion.

-- On EBITDA growth and cash conversion, S&P Global
Ratings-adjusted leverage declines sustainably below 5.0x while the
company clearly commits to maintain conservative credit metrics
within this threshold over the long term.

-- The strong profitability and limited capex needs continue to
translate into FOCF exceeding EUR80 million per year, corresponding
to FOCF to debt sustainably above 10%.

S&P could revise the outlook to stable if:

-- The company is unable to execute its growth strategy or
experiences operating setbacks, leading to weaker EBITDA than
expected and thereby jeopardizing deleveraging prospects, such that
S&P Global Ratings-adjusted leverage would stay above 5.0x for
longer than expected.

-- The company undertakes debt-funded acquisitions or dividend
distributions, resulting in a deterioration of credit metrics.


TELECOM ITALIA: S&P Downgrades LT Rating to 'BB', Outlook Stable
----------------------------------------------------------------
S&P Global Ratings lowering our long-term rating on Telecom Italia
to 'BB' from 'BB+'.

The stable outlook reflects S&P's expectation of adjusted leverage
4.0x-4.5x and funds from operations (FFO) to debt between 12% and
20% over the next two years.

S&P said, "We expect adjusted leverage will continue to rise in
2021 to about 4.3x, from 4.2x in 2020. We now anticipate sharper
organic revenue and EBITDA declines of 3% and 7% respectively
versus the company's previous guidance of low single-digit revenue
growth and a low- to mid-single-digit EBITDA decline. This is the
result of continued fierce competition in the Italian mobile and
fixed-line markets, as well as negative foreign exchange rate (FX)
movements, which offset organic growth in Brazil. Despite improving
trends, including reducing customer attrition, fixed and mobile
revenue continues to decline, due in part to reduced
interconnection tariffs. Meanwhile, a sluggish rebound in roaming
and equipment sales, and weaker benefits from DAZN sports rights
and voucher subsidies, are slowing improvements to revenue. In
Brazil, the negative FX movements on Reis' contributions, although
lessening, have more than offset organic growth in the first nine
months of 2021. Additionally, capital expenditure (capex) for 2021
is expected to remain high, limiting free operating cash flow
(FOCF).

"From 2022, we forecast stabilization in the Italian market,
stronger euro-denominated contributions from Brazil, and lower
capex will support deleveraging. Telecom Italia's average revenue
per user (ARPU) in mobile is modestly improving, supported by
declining mobile number portability. Meanwhile, growth in
ultra-broadband should continue to improve fixed-line trends for
both wholesale and retail. These trends should be supported by
revenue from information and communications technology (ICT)
services, and while not part of our base case, public funding
benefits, including an additional EUR900 million expected under the
broadband voucher program. However, risks remain. The entrance of
Iliad as a fixed broadband competitor could weigh on Telecom
Italia's retail customer base and pricing, but the impact will be
difficult to quantify until its timing and strategy are clear (its
expected launch has been delayed). Moreover, in the longer term,
OpenFiber's gradual deployment of fiber could pressure wholesale
revenue. We also expect more stable contributions from the
Brazilian operations because we forecast less-unfavorable FX
movements from 2022. Combined with incremental profitability
improvements, stable working capital, and lower capex, we expect
adjusted FOCF will rise from a low of about EUR1.7 billion (about
EUR0.9 billion on a reported basis after leases) in 2021. This
should enable Telecom Italia to begin reducing its adjusted
leverage from 2022, although we expect it to remain above 4.0x
until at least 2023.

"An AccessCo transaction could enhance Telecom Italia's fiber
investment and strengthen its competitive position. However, low
visibility on the likelihood and structure of a transaction leads
us to exclude it from our rating analysis. Although a combination
of OpenFiber and Telecom Italia's fixed-line assets would mitigate
long-term competition risk for the wholesale business, we believe
loss of control over the joint assets would likely erode Telecom
Italia's business profile. The terms of any agreement would also be
critical to understanding the financial impact, since significant
debt issuance to retain control could push leverage beyond the
limits of the current rating. Conversely, material proceeds could
in theory help Telecom Italia deleverage and counterbalance a
weakened business profile. In either event, a combined network
entity would have an incentive to expand its wholesale business,
which does not completely align with Telecom Italia's need to
differentiate itself from competing retail broadband operators in
Italy. Over time, this could erode its incumbent advantage, if not
balanced by improvements in the network and the structure of the
broader fiber wholesale market. We are also mindful that this could
create dividend leakage.

"The stable outlook reflects our expectation of adjusted leverage
above 4x and FFO to debt below 20% in 2021 and 2022."

Downside scenario

S&P said, "We could lower the rating if we forecast adjusted
leverage rising, and staying above 4.5x. This could stem from a
return to unsustainable mobile competition that depresses the ARPU
or causes a spike in customer attrition, or from longer term
fixed-line deterioration under wholesale pressure from Openfiber
and retail pressure from new entrants. If, contrary to our current
expectations, Telecom Italia moved to relinquish control over its
fixed network, we could also consider a downgrade based on a weaker
business profile, unless this was offset by a material reduction in
leverage."

Upside scenario

S&P could raise the rating if it expects sustainable adjusted
leverage comfortably below 4.0x, combined with an increase in FFO
to debt above 20%, and FOCF to debt remaining sustainably above
5%.




=====================
N E T H E R L A N D S
=====================

SCHOELLER PACKAGING: Fitch Affirms 'B-' LT IDR, Outlook Stable
--------------------------------------------------------------
Fitch Ratings has affirmed returnable transit packaging
manufacturer Schoeller Packaging B.V.'s Long-Term Issuer Default
Rating (IDR) at 'B-' and the senior secured ratings at 'B-' with a
Recovery Rating of 'RR4'. The Outlook on the IDR is Stable.

The affirmation reflects Fitch's expectations that Schoeller's free
cash flow (FCF) generation will return to negative territory in
2021, due to higher investments, and remain under pressure in the
medium term, which constrains the rating. FCF generation above
Fitch's forecast in 2020 has allowed for moderate deleveraging and
Fitch expects funds from operations (FFO) gross leverage to
gradually improve to 6x in 2023, which is in line with Fitch's
positive rating sensitivity, from a forecast 6.8x in 2021.

The rating of Schoeller is supported by its leading position in its
niche market, a diversified product portfolio and its extended
geographical presence across Europe. Also, successful long-term
co-operation with customers and substantial technology investments
in new products act as effective barriers to entry.

KEY RATING DRIVERS

Accelerating Investments: Innovation leading to development of new
products is key to maintaining competitiveness in the returnable
transit packaging industry and Schoeller has historically invested
heavily in more advanced, higher-margin products. Fitch expects its
new rental business to grow faster than the general business, with
materially higher margins. However, the build-up phase demands
material investment and Fitch forecasts very high capex in
2021-2022 before it gradually normalises. Fitch expects the high
capex to result in negative free cash flow.

Ongoing Pressure on FCF: Fitch expects Schoeller's FCF to turn
negative for 2021, on material increase of capex compared with
2020. Fitch expects this to be partly mitigated by favourable
working-capital movements, but still forecasts an FCF margin of
-2.9% in 2021 and a further weakening to -4.3% in 2022 before it
gradually recovers and turns modestly positive in 2024. The
negative FCF puts pressure on Schoeller's liquidity and constrains
the rating to the low range of the 'B' rating category. Schoeller
generated positive FCF ahead of Fitch's expectations in 2020,
mainly due to improving margins, working-capital release and lower
investments.

Moderate Deleveraging: Apart from a temporary weakened FFO gross
leverage of 6.6x by end-2021, due to stable FFO and a somewhat
higher debt quantum, Fitch expects moderate deleveraging from 2022,
on improving FFO following forecast margin expansion. Fitch expects
Schoeller's FFO gross leverage to reach Fitch's positive rating
sensitivity of 6x by end-2023 and improve towards 5.5x in 2024,
when the company's EUR250 million senior secured notes mature, a
level that is in line with a 'B' category rating.

Rising Input Costs Affecting Margins: Schoeller's revenue and
profitability have in 2021 been affected by volatile resin prices,
which peaked at 90% above normal prices, and shortages of
polypropen (thermo plastic). The company has passed on the higher
costs through price increases, but at the expense of lower demand
from customers and lower Fitch-forecast EBITDA margin in 2021, the
latter due to a time lag in the cost pass-through. Fitch expects
the EBITDA margin to recover to 10.9% in 2022 as resin prices
normalise and to improve further over the medium term on continuous
moderate cost savings and an expanding rental business.

Adequate Business Profile: Fitch views Schoeller's business profile
as solid and commensurate with a 'BB' rating, based on the
company's European market-leading position within its niche, which
includes manufacturing of plastic containers and reusable transit
packaging. Despite a market share of about 20% in Europe, the
rating is constrained by the company's modest scale with
Fitch-forecast revenue of around EUR580 million in 2021, making it
vulnerable to swings in demand. It is, however, partly mitigated by
its geographic diversification in Europe with operations across
some 20 countries, and by an ambition to grow its limited presence
in the US.

Increasing Customer Concentration: Schoeller has a broad customer
base covering a variety of end-markets, but with increasing
concentration in its largest customer in pooling services, IFCO
(Irel Bidco S.a.r.l (B+/Stable)), at almost 28% of total revenue
YTD 3Q21. The business profile is strengthened by a leading product
range consisting of more than 1,000 customisable products. It has a
good record of longstanding relationships as the majority of its
top 100 customers are recurring with relationships often exceeding
15 years.

Environmentally Driven Growth Opportunities: Fitch believes that
reusable plastic containers are set for growth, supported by a
number of trends such as supply-chain efficiency, environmental
awareness and e-commerce development that will drive a transition
to reusable packaging from single-use packaging. Fitch expects
growing demand for a circular economy, favourable regulation and
efforts to cut costs by companies will stimulate demand for
reusable packaging. This development should benefit Schoeller's
products as they are 100% recyclable and have a long lifetime with
an average of 15-20 years, making them sustainable.

DERIVATION SUMMARY

Fitch treats Schoeller as a diversified manufacturer, although
Fitch believes that packaging companies are similar in terms of raw
material usage, environmental impact, logistics, end-markets and
customers, and low FCF generation. The returnable transit packaging
market remains fragmented, but Schoeller has a leading position in
Europe with a 20% market share. Plant locations across Europe allow
Schoeller to be more competitive and to operate at lower
transportation costs than that of peers that usually operate
domestically.

Most of Fitch-rated packaging peers are producing consumers
products (bottles, jars, small packages) and offer a wider range of
products (different material/shapes/colour/marketing), such as
Ardagh Group S.A. (B+/Stable) and Smurfit Kappa Group plc
(BBB-/Stable), while Titan Holdings II B.V. (B/Stable) is focused
on metal packaging. Similarly to Schoeller, they are exposed to a
broad range of end-markets (retail, food, industrial etc.), but are
more affected by market trends resulting from consumer spending and
preferences.

Schoeller has weaker margins than Fitch-rated mid-sized companies
in niche markets, including the belt manufacturer Ammega Group B.V.
(B-/Stable) and Ardagh Group and Titan Holdings. However, Schoeller
has lower FFO gross leverage and they all share modest deleveraging
capacity. The higher rating of IREL Bidco S.a.r.l (B+/Stable),
owner of Schoeller's customer IFCO, reflects its very high EBITDA
margins and long-term contractual flows, despite similar leverage.

KEY ASSUMPTIONS

-- Revenue growth of around 11% in 2021, driven by post-pandemic
    demand and higher prices. Low-to- mid single-digit revenue
    growth 2022-2025;

-- Fitch-adjusted EBITDA margin to decrease to 10.3% in 2021, due
    to time lag in passing on higher input costs to customers.
    This is followed by a recovery in 2022 and to above 12% in
    2024;

-- Working-capital release in 2021, followed by slightly negative
    working capital 2022-2025;

-- Capex peaks in 2021 and remains high in 2022. Normalised capex
    levels in 2023-2025;

-- No M&A activity to 2024;

-- Additional debt drawdown to cover negative FCF;

-- Increased factoring utilisation to EUR60 million from end-
    2021.

KEY RECOVERY ASSUMPTIONS

The recovery analysis assumes that Schoeller would be restructured
as a going concern rather than liquidated in a default.

Fitch applies a distressed enterprise value (EV)/EBITDA multiple of
4.5x to calculate a going-concern EV, reflecting Schoeller's
leading niche market position, long-term customer relationships and
geographic diversification. The multiple is limited by Schoeller's
small size.

Fitch estimates a post-restructuring going-concern EBITDA of EUR47
million.

These assumptions result in a recovery rate for the senior secured
instrument within the 'RR4' range, resulting in equal instrument
rating with the IDR. The principal and interest waterfall analysis
output percentage on current metrics and assumptions is 43%.

RATING SENSITIVITIES

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

-- FFO gross leverage sustainably below 6.0x;

-- Neutral to positive FCF on a sustained basis;

-- Significant growth in size, with evidence of strengthening of
    the business model through revenue growth and continued
    improvements in EBITDA margin to above 12%.

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

-- Deterioration in EBITDA margin towards 9%;

-- FFO gross leverage consistently above 8.0x;

-- Negative FCF on a sustained basis, compromising liquidity;

-- Loss of market share or key customers such as IFCO.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Non-Financial Corporate
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.

LIQUIDITY AND DEBT STRUCTURE

Limited Liquidity: At end-2020, Schoeller's readily available cash
amounted to EUR33 million. Forecast negative FCF of EUR17 million
in 2021 will weigh on the company's cash position, but Fitch's
forecast assumes a EUR10 million drawdown on the revolving credit
facility to maintain a stable cash position. Fitch expects FCF
generation to remain negative in the medium term and assume further
drawdowns on the RCF to cover the cash burn.

Undiversified Debt Structure: The company's debt structure is not
diversified as the vast majority of debt consists of EUR250 million
notes resulting in concentrated maturities in 2024. Liquidity needs
can be covered by Schoeller's EUR30 million RCF, of which EUR28
million was undrawn at end-3Q21, and increased factoring facilities
of EUR100 million (previously EUR70 million), of which EUR47
million was utilised at end-3Q21. Schoeller also has local loans of
around EUR13 million that Fitch treats as senior secured and a EUR9
million unsecured state-guaranteed loan in France.

ISSUER PROFILE

Headquartered in the Netherlands, Schoeller is Europe's largest
manufacturer of plastic containers and reusable transit packaging
with more than 1,000 customisable offered across 10 end-markets.
The company generated revenue of EUR520 million in 2020. In 2018,
the sponsor Brookfield Business Partners L.P. acquired the majority
of Schoeller Packaging B.V.

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.



=========
S P A I N
=========

CODERE LUXEMBOURG 2: Moody's Assigns 'Caa3' CFR, Outlook Stable
---------------------------------------------------------------
Moody's Investors Service has assigned a corporate family rating of
Caa3 and a probability of default rating of Caa3-PD to Codere
Luxembourg 2 S.a.r.l. ("Luxco 2" or "Codere"), the consolidating
holding entity of international gaming company Codere. Moody's has
withdrawn Codere S.A.'s Ca CFR and C-PD/LD PDR. Concurrently,
Moody's has assigned a Ca instrument rating to the EUR228 million
backed subordinated PIK notes due 2027 issued by Codere New Holdco
S.A.. In parallel, Moody's has upgraded Codere Finance 2
(Luxembourg) S.A.'s ("Codere Finance 2") EUR196 million euro
equivalent (split in EUR and $) reinstated backed senior secured
notes due 2027 to Caa3 from Ca and affirmed Codere Finance 2's
EUR482 million amended backed super senior secured notes due 2026
at Caa1. The outlook on the ratings is stable.

Codere announced that it had reached an agreement for the terms of
a proposed restructuring with an ad hoc group of existing
bondholders on April 22, 2021. The terms of the restructuring
included (i) the provision of EUR100 million bridge funding in
April and May this year via the issuance of backed super senior
secured notes, (ii) the provision of an additional EUR125 million
funding in the second half of October that resulted in the recent
issuance of backed super senior notes ("new money"), (iii) an
extension of the maturities of all backed super senior notes and
(iv) a restructuring of the backed senior secured notes.
Post-restructuring, the backed senior secured notes are converted
into three tranches: reinstated backed senior secured notes, backed
subordinated PIK notes and equity.

Moody's views the maturity extension on the backed super senior and
backed senior secured notes and the debt-for-equity swap on the
backed senior secured notes as a distressed exchange, which is an
event of default under Moody's definition of default.

RATINGS RATIONALE

The Caa3 CFR reflects Codere's exposure to potential further
liquidity pressures in the next 12-18 months and concerns over the
sustainability of the company's capital structure in the context of
uncertainties around the pace of recovery in earnings.

Despite the liquidity cushion provided to Codere as part of the
restructuring process, the group's liquidity is weak. A return to
positive free cash flow generation is not expected before the year
2023 such that the liquidity buffer will decrease over time and the
risk of further liquidity pressures remains significant. The
company faces substantial cash outflows in the months to come and
the high interest burden is weighing on the group's cash flows and
profitability.

Post-restructuring, the group's leverage will remain high. The
completion of the restructuring results in a decrease in the
company's total debt and an extension of debt maturities to 2026
and 2027. However although the debt write-off amount is around
EUR360 million which is close to 30% of the pre-restructuring gross
debt, the decrease in debt between the end of 2020 and the date
following the restructuring is limited to around EUR130 million
given the group benefitted from the issuance of bridge notes and
new money notes during the year 2021. As such Moody's expects
leverage (as adjusted by Moody's) to still be above 6 times in 2022
including the impact of the backed subordinated PIK notes even with
a substantial improvement in trading compared to 2021. In addition,
the new terms of the restructured debt include a large PIK interest
component that will increase debt amounts going forward as this
interest will be capitalised. As a result, any decrease in leverage
in the coming years will be driven by the return towards
pre-pandemic levels of EBITDA. The history of regular decline in
revenues in the years preceding the coronavirus crisis from 2017 to
2019, partly due to currencies depreciation, is reflective of the
group's volatile earnings which does not provide comfort as to the
achievability of a steady return to a sustainable level of
profitability.

Furthermore, Codere has a history of being subject to distressed
exchange transactions. The previous distressed exchange was in
October 2020 when Codere closed a refinancing transaction which
resulted in the extension of debt maturities from 2021 to 2023 and
cash injections from bondholders.

Overall, the Caa3 CFR continues to also reflect the group's: (i)
leading market positions in key countries of operation such as
Spain and in Latin America; (ii) moderate diversification by
geography and business segment; (iii) moderate exposure to the
growing online segment. The Caa3 CFR also reflects the following
credit weaknesses: (i) the company's weak liquidity and negative
free cash flow generation, (ii) the group's high adjusted leverage
and high interest burden leading to concerns over the
sustainability of its capital structure, (iii) the risk of more
disruptions related to the pandemic, which would delay a recovery
in operating performance and (iv) the exposure to emerging market
risk and currency fluctuations because of its large presence in
Latin America, especially in Argentina.

STRUCTURAL CONSIDERATIONS

Codere's backed senior secured notes and PDR are in line with the
CFR. The backed super senior secured notes are rated two notches
above the CFR due to their priority over the proceeds in an
enforcement scenario under the terms of the intercreditor
agreement. The backed subordinated PIK notes are rated one notch
below the CFR.

LIQUIDITY

Moody's expects the company's free cash flow to remain negative in
the next 12-18 months such that the cash balance post-restructuring
estimated between EUR175 million and EUR180 million will continue
to be depleted. Post-restructuring, the group does not have
significant debt maturities before the year 2026. Subject to the
uncertainties around the pace of recoveries in earnings, Moody's
expects the post-restructuring liquidity cushion to reduce in the
coming year and be limited towards the end of 2022 potentially
leading to some liquidity pressures.

In the end of June 2021, the group had EUR93 million of cash. The
cash balance in the end of June benefitted from the issuance of
EUR103 million bridge backed super senior secured notes in April
and May. Those bridge backed super senior secured notes issuances
as well as the more recent issuance of EUR129 million new money
notes formed part of the restructuring agreement. The proceeds from
those issuances have been and will be essential in supporting the
group's liquidity in 2021 and 2022.

The company is subject to a liquidity covenant test. The projected
cushion under this liquidity covenant is modest and the covenant
might be breached under more downside scenarios if mitigating
measures are not implemented.

RATIONALE FOR STABLE OUTLOOK

The stable outlook reflects the potential for recovery in operating
performance and credit metrics alongside additional liquidity
headroom afforded by the recently completed restructuring, balanced
by the risks of high cash outflows and liquidity pressures that
could lead to further restructuring actions.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

Upward pressure on the ratings could arise if the company's
performance recovers sustainably such that the risks of liquidity
shortfall or further restructuring reduce.

The ratings could be downgraded if the company's performance fails
to meaningfully recover or if continued large cash outflows lead to
an increasing potential for liquidity shortfall and debt
restructuring with estimates of recovery in an event of default
below levels commensurate with a Caa3 rating.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Gaming
published in June 2021.

LIST OF AFFECTED RATINGS

Upgrades:

Issuer: Codere Finance 2 (Luxembourg) S.A.

BACKED Senior Secured Regular Bond/Debenture, Upgraded to Caa3
from Ca

Assignments:

Issuer: CODERE LUXEMBOURG 2 S.A R.L.

Probability of Default Rating, Assigned Caa3-PD

LT Corporate Family Rating, Assigned Caa3

Issuer: Codere New Holdco S.A.

BACKED Subordinate Regular Bond/Debenture, Assigned Ca

Affirmations:

Issuer: Codere Finance 2 (Luxembourg) S.A.

BACKED Senior Secured Regular Bond/Debenture, Affirmed Caa1

Withdrawals:

Issuer: Codere S.A.

Probability of Default Rating, Withdrawn , previously rated C-PD
/LD

LT Corporate Family Rating (Foreign Currency), Withdrawn ,
previously rated Ca

Outlook Actions:

Issuer: Codere Finance 2 (Luxembourg) S.A.

Outlook, Changed To Stable From Negative

Issuer: CODERE LUXEMBOURG 2 S.A R.L.

Outlook, Assigned Stable

Issuer: Codere New Holdco S.A.

Outlook, Assigned Stable

Issuer: Codere S.A.

Outlook, Changed To Rating Withdrawn From Negative

COMPANY PROFILE

Founded in 1980 and headquartered in Madrid (Spain), Codere is an
international gaming operator. The company is present in nine
countries where it has market leading positions: Spain and Italy in
Europe and Mexico, Argentina, Uruguay, Panama and Colombia in Latin
America. In 2020, the company reported operating revenue of EUR585
million and adjusted EBITDA of EUR23 million.



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

BULB ENERGY: To Be Placed Into "Special Administration"
-------------------------------------------------------
BBC News reports that Bulb Energy, which has 1.7 million customers,
has announced that the firm will be put into administration.

It is the largest UK energy company to face difficulties following
a sharp rise in wholesale gas prices this year, BBC notes.

Bulb will become the first energy company to be placed into
"special administration", where it is run by the government through
the regulator Ofgem, BBC states.

"Customers of Bulb do not need to worry -- Bulb will continue to
operate as normal," BBC quotes Ofgem as saying. "Customers will see
no disruption to their supply and their account and tariff will
continue as normal.  Bulb staff will still be available to answer
calls and queries."

The special administration measure is only used if Ofgem is unable
to find another company to take over an energy firm's customers,
BBC states.  The regulator said it was planning to apply to a court
to appoint an administrator who will run the company, BBC notes.

According to BBC, Bulb said energy supplies were "secure and all
credit balances are protected".

Bulb is the UK's seventh biggest energy company and has 1,000
staff.  It has been trying to shore up its finances for several
weeks.


CONSORT HEALTHCARE: Moody's Cuts Rating on GBP93.3MM Bonds to Ba2
-----------------------------------------------------------------
Moody's Investors Service has downgraded to Ba2 from Baa3 the
underlying and backed ratings for the GBP93.3 million index-linked
guaranteed senior secured bonds due 2041 (the "Bonds") issued by
Consort Healthcare (Tameside) plc ("ProjectCo"), and changed the
outlook to negative from ratings under review. This concludes the
review for downgrade of the ratings that was initiated on July 20,
2021.

RATINGS RATIONALE

The rating action reflects the expiry of the Standstill Agreement
between ProjectCo and the Tameside and Glossop Integrated Care NHS
Foundation Trust (the "Trust") on November 3, 2021, without
agreement on a Heads of Terms ("HoT") for a commercial settlement.
The Standstill Agreement was entered into on the June 22, 2021 for
a three-month period, and had been subsequently extended as the
parties negotiated. During the four months of the standstill,
ProjectCo had been shielded from the majority of deductions, with
an average of GBP178,000 withheld from its monthly Unitary Payment
("UP") compared to GBP489,000 previously. The expiry of the
standstill exposes ProjectCo to the resumption of significant
deductions from its monthly UP, although Moody's understands that
no formal decision will be taken until the Trust board meets on
November 25, 2021 and that some negotiations have continued during
this period.

ProjectCo began to be awarded significant Service Failure Points
("SFPs") and deductions in its November 2020 UP, representing
performance in September 2020, following the Trust bringing in an
independent third-party consultancy, P2G LLP, to monitor the
project. In the 11 months since then, the Trust has awarded 306,783
SFPs and withheld GBP3.5 million from payments to ProjectCo. The
Trust reserves its right to award a further 291,874 SFPs and GBP5.5
million of deductions which have been accrued but not incurred
under the Standstill Agreement. The level of deductions is
equivalent to 29% of the annual UP of GBP12.2 million (or 74% if
the accrued deductions were to be awarded). Moody's understands
ProjectCo is challenging the materiality of some of the defects and
whether the majority of SFP's and deductions have been validly
applied.

When accrued items are included, monthly deductions peaked at
GBP1.8 million in July 2021, representing performance in May 2021,
following the completion of an additional fire stopping survey
requested by the Trust.

Based on the quantum of SFPs awarded, the Trust retains the right
to terminate the Project Agreement with ProjectCo, which was also
the case when the ratings review was initiated. However, Moody's
understands that the Trust has not begun any formal termination
proceedings.

Additionally, Moody's sees an increased risk to ProjectCo from the
amount of rectification works and PFI asset surveys that need to be
undertaken concurrently over the next 18 -- 24 months. Moody's sees
the programming and execution of these works as both a challenge
for ProjectCo and a precursor to rebuilding relationships. A number
of access restrictions may also impede progress, including: (1) an
increased number of COVID-19 positive patients over winter; (2)
high bed occupancy as the Trust deals with a pandemic-induced
backlog of patients; and (3) working restrictions at the Etherow
mental health unit.

Partially mitigating these downsides is Moody's view that the Trust
is cognisant of the financial pressures ProjectCo is under due to
the level of deductions. In September 2021, the Trust returned
GBP1.2 million of previously withheld monies to ProjectCo (while
reserving its right to deduct the amount again in the future),
allowing ProjectCo to meet its September 2021 debt service
obligations in full without the need to draw on reserves. The
12-month historic Debt Service Coverage Ratio ("DSCR") was
therefore 1.10x, compared to an estimated 0.79x without the
additional payment.

Notwithstanding the above pressures, ProjectCo's Ba2 underlying
rating continues to benefit from: (1) the company's long-term
Project Agreement with the Trust with a stable revenue stream; (2)
the credit strength of the Trust supported by a Deed of Safeguard
provided by the Secretary of State; (3) the expectation that there
is a likelihood of high recovery for lenders in the event of any
default by ProjectCo under the PA and termination by the Trust; (4)
the relatively straightforward nature of operation and maintenance
works; and (5) a range of creditor protections included within the
Project's financing structure, such as debt service and maintenance
reserves.

The rating is, however, constrained by: (1) the Project's high
leverage, which reduces its ability to withstand unexpected stress;
and (2) the Project's exposure to hard FM labour cost benchmarking
without the ability to pass increases to the Trust, in addition to
the pressures.

The Bonds benefit from an unconditional and irrevocable guarantee
of scheduled principal and interest from Ambac Assurance UK Limited
(Ambac). However, on April 7, 2011, Moody's ratings on Ambac were
withdrawn and accordingly the backed rating reflects the rating of
the Project on a stand-alone basis.

The negative outlook reflects uncertainty over the future level of
deductions, treatment of the accrued deductions, and ongoing
negotiations between the parties.

Consort Healthcare (Tameside) plc is a special purpose company that
in September 2007 signed a PA with the then Tameside and Glossop
Acute Services NHS Trust to redevelop the existing Tameside General
Hospital site in Ashton-under-Lyne, Greater Manchester and to
provide certain hard FM services until August 2041.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

Given the negative outlook, Moody's currently does not envisage any
upward rating pressure. The outlook could stabilise following a
commercial settlement which limits ongoing deductions and which
substantially reduces or amortises the currently accrued deductions
in a way which limits financial pressure on ProjectCo.

Upward rating pressure would be conditional on: (1) progression of
the outstanding rectification works; (2) the completion of all
required surveys without finding any significant new defects; and
(3) the Trust not having the ability to terminate the Project
Agreement, through SFPs returning below the threshold level.

Conversely, Moody's could downgrade the ratings if: (1) the parties
cannot reach an agreement and deductions continue at high levels;
(2) the accrued deductions are applied in a way which places
additional financial pressure on ProjectCo; (3) the Trust begins
formal termination procedures; (4) Lifecycle cost assumptions were
to prove inadequate; or (5) following a hard FM labour cost
benchmarking exercise, the Project's financial metrics were to
materially deteriorate.

The principal methodology used in these ratings was Operational
Privately Financed Public Infrastructure (PFI/PPP/P3) Projects
Methodology published in June 2021.

PEOPLE'S FIBRE: Dispute with Investors Prompt Administration
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ISPreview reports that alternative UK network ISP People's Fibre,
which started building a new 1Gbps Fibre-to-the-Premises (FTTP)
broadband network in 2020 and soon ran into some challenges with
competition from rivals, has fallen into administration due to a
"breakdown in the relationship" between the company's director and
investors.

The provider had appointed Robert Horton of R2 Advisory Limited as
Administrator on August 26, 2021, ISPreview relates.

According to the administrator's report, which was published on
November 11, 2021, People's Fibre was principally funded by
investor loans (total of GBP1,784,212) via five Swedish based
investors, ISPreview discloses.  But a "breakdown in the
relationship between the director of the Company and Investors"
(the director/CEO is Leo Chong resulted in those investors seeking
an Administration Order on July 23, 2021, ISPreview notes.

According to ISPreview, a statement from the report said "Whilst
the Company was expected to be loss-making in year one, revenue of
approximately GBP580,000 was anticipated.  However, revenue of only
GBP13,000 was generated in the three months preceding the
Administration.  The Company's financial records indicate that
losses of £150,000 were being incurred per quarter."

Metis Partners Ltd has since been called in to help "assist with
the marketing and sale of the Company's business and assets",
ISPreview recounts.  Apparently, there are 11 interested parties
and other formal declarations of interest have been received,
ISPreview notes.  The administrator has opted to keep the ISP
running for 12-weeks while this process is conducted (at an agreed
cost of another c.GBP161,000), ISPreview states.

The administration process became more complicated after the
director, Leo Chong, notified that certain parts of the new fibre
network were likely to be owned by a sister company -- PF Works Ltd
(PFW), upon which Mr. Chong is also a director, ISPreview relays.

"This caused significant and immediate difficulty, both in terms of
offering the business and assets for sale, and in terms of dealing
with trade suppliers, some of whom had contracted directly with
PFW," ISPreview quotes the administrator as saying.

After "protracted" discussions, PFW was placed into Administration
on October 1, 2021, and became part of the same -- now joint --
process as People's Fibre, ISPreview states.  The administrator's
process continues to run, ISPreview notes.


PIERPONT BTL 2021-1: Moody's Gives Ba1 Rating to GBP6.5MM X1 Notes
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Moody's Investors Service has assigned definitive ratings to Notes
issued by Pierpont BTL 2021-1 Plc:

GBP212.1M Class A Mortgage Backed Floating Rate Notes due December
2053, Definitive Rating Assigned Aaa (sf)

GBP21.5M Class B Mortgage Backed Floating Rate Notes due December
2053, Definitive Rating Assigned Aa1 (sf)

GBP9.5M Class C Mortgage Backed Floating Rate Notes due December
2053, Definitive Rating Assigned Aa3 (sf)

GBP5.4M Class D Mortgage Backed Floating Rate Notes due December
2053, Definitive Rating Assigned A1 (sf)

GBP1.5M Class E Mortgage Backed Floating Rate Notes due December
2053, Definitive Rating Assigned Baa1 (sf)

GBP6.5M Class X1 Floating Rate Notes due December 2053, Definitive
Rating Assigned Ba1 (sf)

Moody's has not assigned any ratings to the 2.5M Class X2 Floating
Rate Notes due December 2053.

RATINGS RATIONALE

The notes are backed by a pool of prime UK buy-to-let ("BTL")
mortgage loans originated by LendInvest BTL Limited ("LendInvest",
NR). The pool was acquired by JPMorgan Chase Bank, N.A., London
Branch (Aa1/(P)P-1 & Aa1(cr)/P-1(cr)) from the originator.

The portfolio of assets amounts to approximately GBP 250.0 million
as of September 30, 2021 pool cut-off date. The subordination for
the Class A Notes will be 15.2% excluding the liquidity reserve
fund that will be funded to 1% of the balance of Class A to B Notes
at closing. The liquidity reserve fund is available to pay senior
expenses, interest on Class A and subject to PDL on Class B being
less than 10% of that Class interest on Class B Notes. The release
amounts from the liquidity reserve fund will flow through the
principal waterfall. There is no general reserve fund.

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 static structure and a relatively low
weighted-average loan-to-value ("LTV"). However, Moody's notes that
the transaction features some credit weaknesses such as an unrated
originator with a relatively short history in the BTL space also
acting as servicer and the absence of a balance guaranteed basis
swap. Various mitigants have been included in the transaction
structure such as an experienced delegated servicer, Pepper (UK)
Limited (NR), performing the servicing alongside LendInvest and the
presence of an interest rate swap.

Moody's determined the portfolio lifetime expected loss of 1.4% and
13% MILAN Credit Enhancement ("MILAN CE") related to borrower
receivables. The expected loss captures Moody's expectations of
performance considering the current economic outlook, while the
MILAN CE captures the loss Moody's expect the portfolio to suffer
in the event of a severe recession scenario. Expected defaults and
MILAN CE are parameters used by Moody's to calibrate its lognormal
portfolio loss distribution curve and to associate a probability
with each potential future loss scenario in the ABSROM cash flow
model to rate RMBS.

Portfolio expected loss of 1.4%: This is broadly in line with the
recent UK BTL RMBS sector average and is based on Moody's
assessment of the lifetime loss expectation for the pool taking
into account: (i) the collateral performance of Lendinvest
originated loans to date, with cumulative losses of 0% during the
past 3 years; (ii) the performance of previously securitised
portfolios, with cumulative losses of 0% to date; (iii) very low
satisfied CCJs in the pool; (iv) 21.4% of the loans in the pool
backed by multifamily properties; (v) the current macroeconomic
environment in the UK and the impact of future interest rate rises
on the performance of the mortgage loans; and (vi) benchmarking
with other UK BTL transactions.

MILAN CE for this pool is 13.0%, which is in line with other UK BTL
RMBS transactions, owing to: (i) the WA current LTV for the pool of
72.7%; (ii) top 20 borrowers constituting 9.3% of the pool; (iii)
static nature of the pool; (iv) the fact that all the loans in the
pool are interest-only; (v) the share of self-employed borrowers of
15.8%, and legal entities of 77.8%; (vi) 21.4% of the loans in the
pool backed by multifamily properties; and (vii) benchmarking with
similar UK BTL transactions.

Interest Rate Risk Analysis: 100.0% of the loans in the pool are
fixed rate loans reverting to three months LIBOR or BBR. The Notes
are floating rate securities with reference to daily SONIA. To
mitigate the fixed-floating mismatch between fixed-rate assets and
floating liabilities, there will be a scheduled notional
fixed-floating interest rate swap provided by J.P. Morgan AG
(Aa1(cr)/P-1(cr)).

Principal Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating RMBS Using the MILAN Framework" published in
December 2020.

The analysis undertaken by Moody's at the initial assignment of
ratings for RMBS securities may focus on aspects that become less
relevant or typically remain unchanged during the surveillance
stage.

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

Significantly different actual losses compared with Moody's
expectations at close due to either a change in economic conditions
from Moody's central scenario forecast or idiosyncratic performance
factors would lead to rating actions. For instance, should economic
conditions be worse than forecast, the higher defaults and loss
severities resulting from a greater unemployment, worsening
household affordability and a weaker housing market could result in
a downgrade of the ratings. Deleveraging of the capital structure
or conversely a deterioration in the Notes available credit
enhancement could result in an upgrade or a downgrade of the
ratings, respectively.

PIERPONT BTL 2021-1: S&P Assigns B- (sf) Rating to X1-Dfrd Notes
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S&P Global Ratings has assigned credit ratings to Pierpont BTL
2021-1 PLC's (Pierpont 2021-1) class A notes and class B-Dfrd to
X1-Dfrd interest deferrable notes. At closing, the issuer also
issued X2-Dfrd notes and unrated certificates.

Pierpont 2021-1 is a static RMBS transaction that securitizes a
portfolio of buy-to-let (BTL) mortgage loans secured on properties
in the U.K. LendInvest originated the loans in the pool between
March 2019 and August 2021. The securitized loans are part of a
forward flow agreement between JPMorgan and Lendinvest.

At closing, the issuer used the issuance proceeds to purchase the
full beneficial interest in the mortgage loans from the seller,
JPMorgan Chase Bank, N.A. London Branch. The issuer granted
security over all of its assets in favor of the security trustee.

Credit enhancement for the rated notes consists of subordination
from the closing date and overcollateralization following the
step-up date, which will result from the release of the excess
amount from the liquidity reserve fund to the principal priority of
payments.

The transaction features a liquidity reserve fund to provide
liquidity in the transaction.

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

  Ratings

  CLASS      RATING*    CLASS SIZE (% OF COLLATERAL)

  A          AAA (sf)    84.8

  B-Dfrd     AA- (sf)     8.6

  C-Dfrd     A- (sf)      3.8

  D-Dfrd     BBB- (sf)    2.2

  E-Dfrd     BB (sf)      0.6

  X1-Dfrd    B- (sf)      2.6

  X2-Dfrd    NR           1.0

  Certificates   NR       N/A

*S&P's ratings address timely receipt of interest and ultimate
repayment of principal for the class A notes, and the ultimate
payment of interest and principal on the other rated notes.
N/A--Not applicable.
NR--Not rated.

PURE LEGAL: Lenders Likely to Receive GBP6.4MM of Money Owed
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Neil Rose at Legal Futures reports that two of the Pure Business
Group's main lenders placed the company into administration earlier
this month -- and they are likely to receive the GBP6.4 million
they are owed -- it has emerged.

Regulated law firm Pure Legal was the principal trading entity of
the claims group, eight of whose constituent businesses were put
into administration, and has a book value of GBP56 million,
Legal Futures relays, citing the newly published report of joint
administrators Kroll.

It explained that Novitas historically provided revolving credit
facilities to Pure Legal and Pure Legal Costs Consultants, Legal
Futures discloses.  It is currently owned more than GBP1.8 million,
Legal Futures notes.

In October 2020, in order to provide ongoing liquidity during the
pandemic, Close Invoice Finance -- part of merchant bank Close
Brothers -- provided Pure with a GBP4.6 million Coronavirus
Business Interruption Loan Scheme loan, Legal Futures recounts.

The other secured lender is Perspective Investment Fund, which
since 2017 had advanced Pure GBP6.1 million, Legal Futures states.
Kroll said all three secured lenders should be repaid in full,
according to Legal Futures.

The administrators reported that, in May, Novitas and Close issued
reservation of rights letter in respect of breaches of their
facilities, Legal Futures relays.

In June, Novitas instructed Kroll to conduct a material outsourcing
report and also monitor the response to alleged breaches of the
service level agreement between Novitas and Pure Claims Support
Services, the company that vetted claims and then managed funding
and insurance for them, Legal Futures discloses.

This led on October 14 and October 15 to formal demands for
repayment of GBP6.4 million, Legal Futures states.  On October 20,
with the demands unsatisfied, Novitas and Close applied to put the
companies into administration, Legal Futures recounts.

The order was made on November 2 -- putting more than 200 staff out
of work –- after Pure's efforts to secure other funding to pay
off the debts failed, Legal Futures relays.  It opposed the
administration, Legal Futures notes.

According to Legal Futures, the report said Perspective was
initially opposed too but by the time of the court hearing "no
longer contended that the joint administrators' strategy was
flawed".

Kroll, as cited by Legal Futures, said it had considered whether to
allow Pure to trade in administration whilst a purchaser was
sought, but identified "substantial barriers" to doing so.

These focused on the risks that the dual qualified solicitor and
insolvency practitioner who would have had to lead the
administration would have faced. There would also be a lack of
funding, Legal Futures notes.

Pure Legal's work in progress has a book value of GBP46 million and
Kroll expects to realise around GBP30 million, Legal Futures
discloses.  There are also disbursements worth GBP8.7 million,
Legal Futures states.

As well as the secured creditors, there are two preferential
creditors -- staff owed around GBP11,000 and HM Revenue & Customs,
owed GBP675,000 -- while known secured creditors are owed GBP10.8
million, GBP8.4 million of which relate to intercompany loans,
Legal Futures states.

After-the-event insurer Box Legal is by far the biggest unsecured
creditor to date, owed nearly GBP1.2 million, according to Legal
Futures.

With Kroll estimating that it will realise more than GBP40 million
in total, the odds currently look good for all of Pure Legal's
creditors being paid, Legal Futures states.


ROBIN HOOD: Collapse to Delay City Council's Signing of Accounts
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Matt Jarram at West Bridgford Wire reports that Nottingham City
Council will be 16 months late in signing off its full accounts due
in part to the collapse of Robin Hood Energy and problems related
to valuing its property.

According to West Bridgford Wire, auditors have still not been able
to sign off the full accounts for the year 2019-2020, which should
have been completed on November 30, 2020.

The council has now said it is unlikely the accounts will be ready
until March next year, West Bridgford Wire relates.  Dozens of
other authorities are in a similar position because of ongoing
problems in balancing local authority budgets in the wake of the
pandemic, West Bridgford Wire notes.

The Labour-run authority says it has been unable to finalise the
Statements of Accounts for 2019/20 due to two outstanding issues
which is also impacting the 2020/21 Statement, West Bridgford Wire
states.

These are the collapse of the council-run energy company, Robin
Hood Energy, which collapsed into administration in January 2020,
West Bridgford Wire disclsoes.

Robin Hood Energy auditors, McIntyre Hudson, had completed the
majority of the RHE audit work for 2019/20 but the company went
into administration before the audit was signed, West Bridgford
Wire discloses.

The council, as cited by West Bridgford Wire, said once in
administration, there was no requirement for them to do so or for a
set of accounts to be filed at Companies House.

Avenues are being pursued to obtain accurate financial data up to
the point of entering administration, West Bridgford Wire
discloses.



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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

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Editors.

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