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

                          E U R O P E

          Thursday, December 9, 2021, Vol. 22, No. 240

                           Headlines



A U S T R I A

SCHUR FLEXIBLES: S&P Assigns 'B' Long-Term ICR, Outlook Stable


B E L A R U S

EUROTORG LLC: Fitch Affirms 'B' LT IDR, Outlook Negative


C R O A T I A

[*] CROATIA: To Launch Early Warning System for Distressed Cos.


I R E L A N D

HARVEST CLO XXV: Fitch Rates Class F Tranche Final 'B-'
HARVEST CLO XXV: S&P Assigns B- (sf) Rating to Class F-R Notes
MUNSTER STRATEGIC: Gets Okay to Apply for Appointment of Examiner


I T A L Y

BCC NPL 2018-2: DBRS Confirms CCC Rating on Class B Notes
EBLA SRL: DBRS Confirms CCC Rating on Class B Notes
POPOLARE BARI: DBRS Lowers Class A Notes Rating to CCC


M O N T E N E G R O

KAP: Elektroprivreda Crne Gore Denies Rumor on Acquisition Bid


R U S S I A

RAVNAQ BANK: S&P Affirms 'B-/B' ICRs, Outlook Still Negative


U N I T E D   K I N G D O M

GFG ALLIANCE: Making Great Progress in Recovery, Chairman Says
HELIOS DAC: DBRS Confirms B(high) Rating on Class E Notes
MCE INSURANCE: Bikers May Lose 10% of Claim Value
RIBBON FINANCE 2018: DBRS Confirms BB(low) Rating on Class F Notes
WESWAP: Bought Out of Administration by Blackthorn Finance

[*] DBRS Places Ratings of 6 UK RMBS Transactions Under Review

                           - - - - -


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

SCHUR FLEXIBLES: S&P Assigns 'B' Long-Term ICR, Outlook Stable
--------------------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to Schur Flexibles GmbH (Schur) and its 'B' issue rating to the
senior secured term loan B. The recovery rating on the senior
secured term loan B is '3', indicating its expectation of
meaningful recovery (rounded estimate: 50%) in the event of a
payment default.

S&P said, "The stable outlook reflects our expectation that despite
weak free operating cash flow (FOCF) in 2021, Schur will generate
modest but positive FOCF from 2022. At the same time, we expect
leverage of about 5.8x in 2021 and 5.5x-5.7x in 2022, supported by
S&P Global Ratings-adjusted EBITDA margins of 15%-16% and strong
organic growth."

Austria-based investment holding company B&C Group acquired 80% of
flexible packaging maker Schur Flexibles Holding GesmbH from
Lindsay Goldberg in May 2021. As a part of this acquisition, Schur
refinanced its existing debt with a EUR475 million senior secured
term loan B maturing in 2028, alongside a EUR100 million senior
secured revolving credit facility (RCF).

S&P expects Schur's adjusted EBITDA margins to remain stable at
around 15%-16% in the near term, as the small size of the business
remains a rating constraint. Schur's adjusted EBITDA margin
improved to around 16% in 2020 thanks to polymer procurement
savings, geographical footprint rationalizations, favorable changes
in the product mix, and additional sales volumes. The rating
remains constrained by Schur's limited scale of operations,
however. The flexible packaging market is highly fragmented and
competitive. Schur is the fourth-largest flexible packaging
producer in Europe, with a market share of around 3%. It is smaller
and less geographically diverse than the top three European
players: Amcor PLC, Mondi PLC, and Constantia Flexibles.

Schur has some raw material price exposure, mainly to resin. In
about 70% of sales, the company has no resin price exposure, as
input costs are directly passed through to end customers. The
remaining 30% of sales contracts stipulate resin price pass-through
mechanisms (quarterly adjustments), whereby Schur is able to pass
on price increases with a typical industry time lag of three-to-six
months. The purchasing power of its polymer trading division, which
purchases around twice the volumes that Schur consumes, generally
results in lower resin prices than smaller peers.

Despite weaker FOCF in 2021, Schur will continue to generate strong
FOCF from 2022. After strong adjusted FOCF generation in 2020,
Schur is likely to generate limited FOCF in 2021 of less than EUR5
million, primarily due to working capital swings, as a shortage of
raw materials has caused a temporary spike in inventory levels.
Thereafter, S&P expects modest FOCF generation of more than EUR20
million, supported by growth in EBITDA and moderate working capital
swings.

S&P said, "Our assessment of Schur's financial risk profile
reflects our expectation of adjusted debt to EBITDA of about 5.8x
at year-end 2021, following the refinancing transaction. We expect
that adjusted leverage will decline to about 5.5x-5.7x in 2022,
driven by solid organic revenue and EBITDA growth. We have not
assumed any acquisitions but do not rule out opportunistic bolt-on
acquisitions.

"The ratings are in line with the preliminary ratings we assigned
on Sept. 7, 2021, following the close of the transaction and our
review of the final documentation.

"The stable outlook reflects our expectation that despite weak FOCF
in 2021, Schur will generate modest but positive FOCF from 2022. At
the same time, we expect leverage of about 5.8x in 2021 and
5.5x-5.7x in 2022, supported by adjusted EBITDA margins of 15%-16%
and strong organic growth.

"We might lower the rating if Schur's operating performance
deteriorates, if the company adopts a more aggressive financial
policy such that adjusted debt to EBITDA rises above 7.5x for a
prolonged period, or if Schur generates negative FOCF for a
sustained period.

"An upgrade is unlikely within the next year, but we could raise
the rating in the longer term if the company deleverages to below
5x on a sustained basis and demonstrates that it is committed to a
less aggressive financial policy and to achieving higher EBITDA
margins."




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B E L A R U S
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EUROTORG LLC: Fitch Affirms 'B' LT IDR, Outlook Negative
--------------------------------------------------------
Fitch Ratings has affirmed LLC Eurotorg's Long-Term Issuer Default
Rating (IDR) at 'B' with Negative Outlook.

The rating of Eurotorg reflects its small scale, limited
diversification outside its domestic market and high
foreign-exchange (FX) risks, which weigh on its financial
flexibility relative to rated sector peers'. These weaknesses are
balanced against its conservative capital structure and a strong
position in Belarus's food retail market. Fitch believes that the
rating can accommodate increasing competitive pressures from hard
discounters, as seen recently, and that Eurotorg is well-positioned
to retain its leading market share.

The Negative Outlook is in line with that on Belarus's sovereign
rating (B/Negative) and reflects the risk of a downgrade of
Belarus's Country Ceiling to below 'B'. This factor currently
constrains Eurotorg's rating.

KEY RATING DRIVERS

Country-Ceiling Constraint: The Negative Outlook on Eurotorg's IDR
is aligned with the Outlook on Belarus's sovereign rating and
reflects risks of a downgrade of Belarus's Country Ceiling to below
'B'. The Country Ceiling constrains Eurotorg's rating as the
company does not have export earnings and foreign assets and
financial support from a foreign parent or strategic partners,
which may allow the rating to be above the applicable Country
Ceiling.

Competition from Hard Discounters: Consumer interest in hard
discounter format has been increasing in Belarus over the past five
years and Fitch believes that competition from hard discounters,
including Russian Svetofor and Dobrotsen, has intensified. To fend
off competition, Eurotorg ensures its selling prices remain
attractive to consumers and also develops its new soft- and
hard-discounter formats, which together accounted for almost 25% of
its retail sales in 1H21. Fitch does not expect increased
competition to weaken Eurotorg's credit profile, although it may
put some pressure on its profitability and cash generation.

EBITDA Margin Improvement: Eurotorg improved its Fitch-adjusted
EBITDA margin to 9% in 2020 from 6.5% in 2019, due to improved
commercial terms by shortening payment deferrals with suppliers,
renegotiation of rents and staff-cost optimisation. Fitch assumes
that EBITDA margin may reduce to around 8% over the medium term as
Eurotorg's like-for-like (LfL) sales will lag behind inflation, due
to prices being kept low and competitive.

Working-Capital Investment to Moderate: Fitch expects Eurotorg's
cash generation in 2021 will be affected by fewer payment deferrals
with suppliers and increased stock levels. However, Fitch assumes
the related cash outflow in 2021 would be around BYN100 million
lower than 2020's BYN264 million and would not exceed BYN50 million
a year over 2022-2024. Eurotorg may change payment terms with
suppliers to attain purchasing-price benefits, which could then be
passed onto consumers.

FCF to Turn Positive: Fitch expects the free cash flow (FCF) margin
to turn positive and gradually improve to above 2% over 2021-2024
(2020: -1.5%), which is solid for the rating, and is driven by
lower investments in working capital. This is despite higher capex
associated with an increased number of planned new store openings.
Fitch also assumes Eurotorg will continue pursuing its capex-light
expansion strategy and will open primarily small leasehold stores.

Moderate Leverage: Eurotorg has been operating under moderate funds
from operations (FFO) adjusted gross leverage of 3.8x-4.0x over the
past four years. Fitch expects leverage to remain slightly below
its positive rating sensitivity of 4x over 2021-2024, assuming no
sharp local-currency devaluation. Its solid financial structure is
commensurate with a 'B+' rating, but any positive rating action is
constrained by the Country Ceiling. Leverage parameters for
Eurotorg's rating are aligned with higher-rated peers' as the
company's more conservative capital structure offsets FX risks and
the volatility of operating performance.

Largest Food Retailer in Belarus: The rating is supported by
Eurotorg's strong market position as the largest food retailer in
Belarus, with a stable 19% market share by sales over the past five
years. This is around 4x its largest competitor's. The company
benefits from its well-recognised Euroopt brand across the country
and from increased consumer appeal for its new discounter banners
Hit! and Groshyk.

Small Scale, Limited Diversification: The rating considers
Eurotorg's limited geographic diversification as the company
operates only in Belarus. Presence across different regions of the
country puts it in a stronger position than competitors, but does
not reduce concentration risks, as Belarus is a small economy. The
small size of the domestic market also leads to Eurotorg's
substantially smaller business scale (2020 EBITDAR of around USD240
million-equivalent) than that of other Fitch-rated food retailers,
such as Russian retailers X5 Retail Group N.V. and Lenta LLC.

High FX Risks: Eurotorg faces high FX risks as its debt is solely
in foreign currency, while its revenue is in Belarusian roubles. In
addition, part of Eurotorg's costs (2020: 2.5% of revenue) is also
exposed to FX as operating-lease agreements are primarily in hard
currency (93% of total rental payments). Fitch estimates that a 30%
devaluation of the Belarusian rouble against hard currencies may
drive up to an 1.0x leverage increase under Fitch's conservative
assumption that selling prices do not increase in line with
resulting inflation.

Russian-Rouble Funding Partial Mitigation: Fitch assumes that weak
financial-market development in Belarus will not allow the company
to fully switch the currency of its debt and operating-lease
agreements to Belarusian roubles over the medium term.
Nevertheless, funding in Russian roubles (1H21: 39% of total debt
after swap) provides some financial flexibility as Belarusian and
Russian roubles have shown some correlation in the past.

DERIVATION SUMMARY

Eurotorg's market position and bargaining power in Belarus is
stronger than those of Russian peers X5 (BB+/Stable) and Lenta
(BB+/Stable) in their respective markets. This is due to the large
distance in market share between Eurotorg and its next competitor,
and significant price advantage. However, in annual absolute
EBITDAR, Eurotorg is substantially smaller than its Russian peers
and has material exposure to FX risks, while it has a similar
leverage profile. As a result, Eurotorg is rated lower than its
Russian peers.

Eurotorg's ratings also take into consideration higher-than-average
systemic risks associated with the Belarusian business and
jurisdictional environment.

Eurotorg's IDR is constrained by the Country Ceiling of Belarus.
The Negative Outlook is in line with the Outlook on Belarus's
sovereign rating and reflects risks of a downgrade of Belarus's
Country Ceiling to below 'B'.

KEY ASSUMPTIONS

Fitch's key assumptions within its rating case for the issuer
include:

-- US dollar/Belarusian rouble at 2.5 at end-2021, 2.6 at end-
    2022 and 2.8 at end-2023;

-- CAGR of 5% in selling space in 2021-2024;

-- Low single-digit LfL sales growth in 2021-2023;

-- EBITDA margin to decline to 8.3% in 2021 and stabilise at 8%
    in 2022-2024;

-- Working-capital outflow of around BYN146 million in 2021,
    followed by around BYN50 million annually to 2024;

-- Capex at around BYN100 million a year over 2021-2024;

-- Dividends not exceeding USD25 million a year over 2021-2024;

-- No M&A in 2021-2024.

KEY RECOVERY RATING ASSUMPTIONS

Eurotorg's USD300 million loan participation notes (LPNs) are
issued by Bonitron Designated Activity Company, an SPV domiciled in
Ireland to only issue notes and provide a loan to Eurotorg. The
notes are secured by a loan to Eurotorg, which ranks equally with
the company's other senior unsecured obligations. Eurotorg is the
major operating company within the Eurotorg group, accounting for
most of the group's assets and EBITDA.

Our recovery analysis assumes that Eurotorg would be a going
concern in bankruptcy and that it would be reorganised rather than
liquidated. Fitch has assumed a 10% administrative claim.

Eurotorg's going-concern EBITDA of USD110 million is 38% below
Fitch-adjusted EBITDA of USD159 million for LTM to end-June 2021.
It considers the company's high FX risks and reflects Fitch's view
of a sustainable, post-reorganisation EBITDA level, upon which
Fitch based the valuation of the company.

Fitch uses an enterprise value/EBITDA multiple of 4.0x to calculate
a post-reorganisation valuation, reflecting a mid-cycle multiple.
This is in line with the enterprise-value multiple Fitch uses for
Ukrainian poultry producer MHP. For Fitch's debt-waterfall
assumptions, Fitch used the group's debt at 30 June 2021. Lease
liabilities were not included in the debt waterfall, in line with
Fitch's criteria.

Eurotorg's USD64 million of secured debt ranks ahead of the LPNs in
the waterfall. For the purpose of recovery calculation, Fitch used
an LPN amount of around USD200 million, representing an external
debt obligation, as around USD100 million is repurchased by the
company but not redeemed. The waterfall analysis generated a ranked
recovery for senior unsecured LPNs in the 'RR3' band, indicating a
higher rating than the IDR as the waterfall analysis output
percentage on current metrics and assumptions was 58%. However, the
LPNs are rated in line with Eurotorg's IDR of 'B' as notching up is
not possible, due to the Belarusian jurisdiction. Therefore, the
Recovery Rating is capped at 'RR4' with a waterfall analysis output
percentage also capped at 50%.

RATING SENSITIVITIES

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

-- Fitch would consider revising Eurotorg's Outlook to Stable if
    the Outlook on Belarus's sovereign rating is revised to
    Stable;

-- An upgrade of the Belarus Country Ceiling would be a
    prerequisite for any upgrade;

-- Successful execution of expansion strategy as demonstrated by
    growing LfL sales and stable profitability, leading to FFO
    adjusted gross leverage below 4.0x and FFO fixed-charge
    coverage above 2x on a sustained basis;

-- Sustained positive FCF and maintenance of a conservative
    financial policy;

-- Adequate access to external liquidity.

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

-- Sustained operating underperformance, including declining LfL
    sales and profitability leading to FFO adjusted gross leverage
    above 5.0x and FFO fixed-charge coverage below 2x on a
    sustained basis;

-- Negative FCF;

-- Inability to obtain sufficient funding 12-18 months ahead of
    large debt maturities;

-- Downgrade of the Belarus Country Ceiling.

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

Comfortable Liquidity: At end-June 2021, Eurotorg had sufficient
liquidity as reported cash of BYN208 million (excluding cash at
related-party bank Statusbank, which Fitch fully deconsolidates),
together with projected positive FCF generation was sufficient to
cover short-term debt of BYN34 million. Fitch does not expect any
major near-term refinancing needs as the majority of borrowings
comes due after 2022 with the largest maturity being in 2025
(Eurobond).

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.

ISSUER PROFILE

Eurotorg is the largest retailer in Belarus's grocery retail
market.



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C R O A T I A
=============

[*] CROATIA: To Launch Early Warning System for Distressed Cos.
---------------------------------------------------------------
Annie Tsoneva at SeeNews reports that Croatia's government approved
a plan to launch an early warning system for debtors in financial
distress, aiming to help companies avoid bankruptcy and provide
additional protection of the rights of the employees of companies
in bankruptcy proceedings, justice and public administration,
minister Ivan Malenica said on Dec. 2.

According to SeeNews, the system will be introduced through
amendments to the bankruptcy law which the government is proposing
to parliament to approve, including re-defining of the conditions
for appointing receivers at distressed companies, Malenica told a
weekly cabinet meeting.





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I R E L A N D
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HARVEST CLO XXV: Fitch Rates Class F Tranche Final 'B-'
-------------------------------------------------------
Fitch Ratings has assigned Harvest CLO XXV Designated Activity
Company's final ratings.

    DEBT                          RATING
    ----                          ------
Harvest CLO XXV DAC - Reset

A XS2405859286              LT AAAsf   New Rating
B-1 XS2405859369            LT AAsf    New Rating
B-2 XS2405859799            LT AAsf    New Rating
C XS2405859955              LT Asf     New Rating
D XS2405860029              LT BBB-sf  New Rating
E XS2405860532              LT BB-sf   New Rating
F XS2405860706              LT B-sf    New Rating
Subordinated XS2240270954   LT NRsf    New Rating
Z XS2240270871              LT NRsf    New Rating

TRANSACTION SUMMARY

Harvest CLO XXV DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of senior unsecured,
mezzanine, second-lien loans and high-yield bonds. Net proceeds
from the issuance of the notes have been used to redeem existing
notes (excluding the class Z and subordinated notes) and upsize the
portfolio to EUR475 million at the reset date. The portfolio will
be actively managed by Investcorp Credit Management EU Limited. The
collateralised loan obligation (CLO) has a 4.6-year reinvestment
period and an 8.5-year weighted average life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors to be in the 'B'/'B-' category.
The Fitch weighted average rating factor (WARF) of the identified
portfolio is 25.74.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise senior secured obligations. Fitch views the
recovery prospects for these assets as more favourable than for
second-lien, unsecured and mezzanine assets. The Fitch weighted
average recovery rate (WARR) of the identified portfolio is
62.60%.

Diversified Asset Portfolio (Positive): The transaction includes
two Fitch matrices: one effective at closing corresponding to a top
10 obligor concentration limit at 20% and a fixed-rate asset limit
of 10%; and one that can be selected by the manager at any time
from one year after closing as long as the portfolio balance
(including defaulted obligations at their Fitch collateral value)
is above target par and subject to the same limits as the previous
matrix. The transaction also includes various concentration limits,
including the maximum exposure to the three largest (Fitch-defined)
industries in the portfolio at 40%. These covenants ensure that the
asset portfolio will not be exposed to excessive concentration.

Portfolio Management (Neutral): The transaction has a 4.6-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed-case portfolio with the aim of testing the robustness of
the transaction structure against its covenants and portfolio
guidelines.

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

RATING SENSITIVITIES

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

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

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

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

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

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

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

Harvest CLO XXV DAC - Reset

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

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

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.

HARVEST CLO XXV: S&P Assigns B- (sf) Rating to Class F-R Notes
--------------------------------------------------------------
S&P Global Ratings assigned its 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 did 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 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                     2,925.85
  Default rate dispersion                                  416.37
  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 (%)                            2.74
  '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 said, "Our 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 ratings
are commensurate with the available credit enhancement for the
class A-R, D-R, and 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 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 'B- (sf)' 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 S&P rates, and that has recently
been issued in Europe.

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

-- S&P's model generated break-even default rate 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 we envision 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, the transaction's documented
counterparty replacement and remedy mechanisms are in line with our
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, the issuer is bankruptcy remote, in line with our
legal criteria.

"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 each class
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, "How Credit Distress Due To COVID-19 Could Affect
European CLO Ratings," published on April 2, 2020.

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

  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.
  EURIBOR--Euro Interbank Offered Rate.



MUNSTER STRATEGIC: Gets Okay to Apply for Appointment of Examiner
-----------------------------------------------------------------
Ray Managh at The Irish Times reports that the owner of the
Kilcoran Lodge Hotel in Tipperary was granted leave to apply for
the appointment of an examiner on Dec. 7 in the Circuit Civil Court
in an attempt to save the business and 37 jobs.

According to The Irish Times, Barrister Ross Gorman told Judge
Cormac Quinn that while the company, Munster Strategic Investments,
was unable to pay its debts, an independent expert was of the view
it could be rescued through the appointment of an examiner.

Mr. Gorman said the company had been incorporated in November 2015
by directors Paul Bowes and his daughter Triona Bowes, both of
Mocklers Hill, Cashel, but had hit financial difficulties mainly
due to the coronavirus pandemic, The Irish Times relates.

He said the company commenced trading in 2018 and, following a slow
start due to ongoing enhancement works trade, had been unexpectedly
affected by the pandemic last year, forcing its closure from March
to July 2020, The Irish Times recounts.

He said the company had suffered significant losses since
commencing trading in 2018 and one of the Chinese investors was now
seeking repayment of a loan that the company was unable to meet,
The Irish Times relays.

The company would apply for the appointment of Joseph Walsh of JW
Accountants, Grand Canal Street Upper, Dublin, who had agreed to
act as examiner if appointed, according to The Irish Times.

He said independent expert Aiden Murphy believed the company -- and
jobs associated with it -- could be saved under a scheme of
arrangement developed by Mr. Walsh if given court protection
against its creditors, The Irish Times notes.

The judge, as cited by The Irish Times, said he would allow an
application for the appointment of an examiner to be made on Dec.
17.




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

BCC NPL 2018-2: DBRS Confirms CCC Rating on Class B Notes
---------------------------------------------------------
DBRS Ratings GmbH confirmed its BB (high) (sf) and CCC (sf) ratings
of the Class A Notes and Class B Notes, respectively, issued by BCC
NPLs 2018-2 S.r.l. (the issuer). The trends remain Negative for
both classes of notes.

The transaction represents the issuance of Class A Notes, Class B
Notes, and Class J Notes (collectively, the Notes). The rating
assigned to the Class A Notes addresses the timely payment of
interest and the ultimate payment of principal on or before its
final maturity date in July 2042. The rating assigned to the Class
B Notes addresses the ultimate payment of both interest and
principal. DBRS Morningstar does not rate the Class J Notes.

At issuance, the Notes were backed by a EUR 2 billion portfolio by
gross book value consisting of a mixed pool of Italian
nonperforming residential mortgage loans, commercial mortgage
loans, and unsecured loans originated by a pool of 73 Italian
banks.

The receivables are serviced by doValue S.p.A. (the Servicer),
while Securitization Services S.p.A., operates as backup servicer.

RATING RATIONALE

The confirmations follow a review of the transaction and are based
on the following analytical considerations:

-- Transaction performance: assessment of portfolio recoveries as
of June 30, 2021, focusing on: (1) a comparison between actual
collections and the Servicer's initial business plan forecast (the
Business Plan); (2) the collection performance observed over the
past months, including the period following the outbreak of the
Coronavirus Disease (COVID-19); and (3) a comparison between the
current performance and DBRS Morningstar's expectations.

-- Portfolio characteristics: loan pool composition as of
September 2021 and the evolution of its core features since
issuance.

-- The transaction liquidating structure: the order of priority
entails a fully sequential amortization of the notes (i.e., the
Class B Notes will begin to amortize following the full repayment
of the Class A Notes, and the Class J Notes will amortize following
the repayment of the Class B Notes).

-- Performance ratios and underperformance events: as per the most
recent July 2021 investor report, the cumulative collection ratio
is 80.34% and the net present value cumulative profitability ratio
is 118.69%. The 80% trigger has been not breached for both the
cumulative collection ratio and the net present value cumulative
profitability ratio.

-- Liquidity support: the transaction benefits from an amortizing
cash reserve providing liquidity to the structure and covering
against potential interest shortfall on the Class A Notes. The cash
reserve, which has a target amount equal to 3% of the Class A Notes
principal outstanding balance, is currently fully funded.

TRANSACTION AND PERFORMANCE

According to the latest payment report from July 2021, the
outstanding principal amounts of the Class A Notes, Class B Notes,
and Class J Notes were EUR 416.2 million, EUR 60.1 million, and EUR
20.0 million, respectively. The balance of the Class A Notes has
amortized by approximately 12.9% since issuance. The current
aggregated transaction balance is EUR 496.4 million.

As of June 2021, the transaction was performing below the
Servicer's business plan expectations. The actual cumulative gross
collections equaled EUR 132.3 million whereas the Servicer's
business plan estimated cumulative gross collections of EUR 158.4
million for the same period. Therefore, as of June 2021, the
transaction was underperforming by EUR 26.2 million (-16.5%)
compared with the business plan expectations.

In November 2020 annual review, DBRS Morningstar estimated
cumulative gross collections for the same period of EUR 144.0
million at the BB (high) (sf) stressed scenario. Therefore, as of
June 2021, the transaction was performing below DBRS Morningstar's
BB (high) (sf) stressed expectations according to the November 2020
annual review.

In April 2021, the Servicer delivered an updated portfolio business
plan (Updated BP) as of December 2020, which is the first update
since issuance. The Updated BP, combined with the actual cumulative
gross collections of EUR 104.2 million as of December 31, 2020,
results in a total of EUR 764.5 million expected gross collections,
which is 8.0% lower than the total gross collections of EUR 830.6
million estimated in the initial business plan. Without including
actual collections, the Servicer' expected future collections from
January 2021 are now accounting for EUR 660.4 million (EUR 711.4
million in the initial business plan). Hence, the Servicer'
expectation for collection on the remaining portfolio was revised
considerably downwards. The updated DBRS Morningstar BB (high) (sf)
rating stress assumes a haircut of 15.2% to the Servicer's updated
business plan, considering total future expected collections from
July 2021 onwards. In DBRS Morningstar's CCC (sf) scenario, the
Servicer's updated forecast was only adjusted in terms of actual
collections to date, and timing of future expected collections.

The final maturity date of the transaction is in July 2042.

DBRS Morningstar analyzed the transaction structure using Intex
DealMaker.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases increases in unemployment rates and income reductions
for many borrowers. DBRS Morningstar anticipates that negative
effects may continue in the coming months for many nonperforming
loan (NPL) transactions. In particular, the deterioration of
macroeconomic conditions could negatively affect recoveries from
NPLs and the related real estate collaterals. The rating is based
on additional analysis to expected performance as a result of the
global efforts to contain the spread of the coronavirus. For this
transaction, DBRS Morningstar incorporated its expectation of a
moderate medium-term decline in residential property prices, but
gave partial credit to house price increases from 2023 onward in
non-investment-grade scenarios.

Notes: All figures are in euros unless otherwise noted.


EBLA SRL: DBRS Confirms CCC Rating on Class B Notes
---------------------------------------------------
DBRS Ratings GmbH changed the trends on the Class A and Class B
notes issued by Ebla S.r.l. (the Issuer) to Stable from Negative
and confirmed the ratings at BBB (low) (sf) and CCC (sf),
respectively.

The transaction was funded by the issuance of Class A, Class B, and
Class J notes (collectively, the Notes). The rating on the Class A
notes addresses the timely payment of interest and the ultimate
payment of principal while the rating on the Class B notes
addresses the ultimate payment of both interest and principal. DBRS
Morningstar does not rate the Class J notes.

At issuance, the Notes were backed by a EUR 348.6 million by gross
book value portfolio consisting of secured and unsecured Italian
nonperforming loans originated by Banca Agricola Popolare di Ragusa
S.C.p.A. (the Originator).

The receivables are serviced by doValue S.p.A. (the Servicer) while
Securitization Services S.p.A. operates as backup servicer.

RATING RATIONALE

The confirmations follow a review of the transaction and are based
on the following analytical considerations:

-- Transaction performance: assessment of portfolio recoveries as
of September 30, 2021, focusing on: (1) a comparison between actual
collections and the Servicer's initial business plan forecast; (2)
the collection performance observed over the past months, including
the period following the outbreak of the Coronavirus Disease
(COVID-19); and (3) a comparison between the current performance
and DBRS Morningstar's expectations.

-- Portfolio characteristics: loan pool composition as of
September 2021 and the evolution of its core features since
issuance.

-- The transaction liquidating structure: the order of priority
entails a fully sequential amortization of the Notes (i.e., the
Class B notes will begin to amortize following the full repayment
of the Class A notes and the Class J notes will amortize following
the repayment of the Class B notes).

-- Performance ratios and underperformance events: as per the most
recent October 2021 payment report, the cumulative collection ratio
was 78% and the net present value cumulative profitability ratio
was 138%. Since the April 2021 interest payment date, the
cumulative collection ratio has breached the 85% limit, so that
Class B interest payments are subordinated to the repayment of the
Class A principal.

-- Liquidity: the transaction benefits from an amortizing cash
reserve providing liquidity to the structure, covering potential
interest shortfalls on the Class A notes and senior fees. The cash
reserve target amount is equal to 7.5% of the principal outstanding
on the Class A notes and is currently fully funded.

TRANSACTION AND PERFORMANCE

According to the latest payment report from October 2021, the
outstanding principal amounts of the Class A, Class B, and Class J
notes were EUR 51.1 million, EUR 9.0 million, and EUR 3.5 million,
respectively. The balance of the Class A notes has amortized by
approximately 39.9% since issuance. The current aggregated
transaction balance is EUR 63.6 million.

As of September 2021, the transaction was performing below the
Servicer's business plan expectations. The actual cumulative gross
collections equaled EUR 51.4 million whereas the Servicer's initial
business plan estimated cumulative gross collections of EUR 63.6
million for the same period. Therefore, as of September 2021, the
transaction was underperforming by EUR 12.2 million (-19.2%)
compared with the business plan expectations.

At issuance, DBRS Morningstar estimated cumulative gross
collections for the same period of EUR 23.9 million at the BBB
(low) (sf) stressed scenario. Therefore, as of September 2021, the
transaction was performing above DBRS Morningstar's stressed
expectations.

In April 2021, the Servicer delivered an updated portfolio business
plan as of December 2020. The updated portfolio business plan,
combined with the actual cumulative gross collections of EUR 38.9
million as of 31 December 2020, results in a total of EUR 150.7
million, which is 9.7% lower than the total gross collections of
EUR 166.8 million estimated in the initial business plan. The
updated DBRS Morningstar BBB (low) (sf) rating stress assumes a
haircut of 21.7% to the Servicer's updated business plan,
considering future expected collections from October 2021. In DBRS
Morningstar's CCC (sf) scenario, the Servicer's updated forecast
was only adjusted in terms of actual collections to date and timing
of future expected collections.

Considering the high profitability ratio registered since issuance
and the increased credit enhancement, the rated bonds would now
pass higher rating stresses in the cash flow analysis.
Nevertheless, according to the updated business plan delivered in
April 2021, the Servicer's expectations on future gross collections
have been reduced and aggregate gross collections have
underperformed original business plan expectations since issuance.

In light of the above DBRS Morningstar does not think this
performance trend is yet sustainable in the medium to long term and
confirmed the current ratings assigned to the Class A and Class B
notes. However, considering the current profitability level of the
transaction, the rating trend assigned to the Class A and Class B
notes has been changed to Stable from Negative.

The final maturity date of the transaction is in April 2037.

DBRS Morningstar analyzed the transaction structure using Intex
DealMaker.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases increases in unemployment rates and income reductions
for many borrowers. DBRS Morningstar anticipates that negative
effects may continue in the coming months for many nonperforming
loan (NPL) transactions. In particular, the deterioration of
macroeconomic conditions could negatively affect recoveries from
NPLs and the related real estate collaterals. The ratings are based
on additional analysis to expected performance as a result of the
global efforts to contain the spread of the coronavirus. For this
transaction, DBRS Morningstar incorporated its expectation of a
moderate medium-term decline in residential property prices, but
gave partial credit to house price increases from 2023 onward in
non-investment-grade scenarios.

Notes: All figures are in euros unless otherwise noted.


POPOLARE BARI: DBRS Lowers Class A Notes Rating to CCC
------------------------------------------------------
DBRS Ratings GmbH downgraded its ratings on the bonds issued by
Popolare Bari NPLS 2016 S.r.l. (the Issuer) as follows:

-- Class A Asset Backed Floating Rate Notes due 2036 (the Class A
Notes) to CCC (sf) from BB (sf)

-- Class B Asset Backed Floating Rate Notes due 2036 (the Class B
Notes) to CC (sf) from CCC (sf)

The transaction was funded by the issuance of Class A, Class B, and
Class J Notes (collectively, the Notes). The rating on the Class A
Notes addresses the timely payment of interest and the ultimate
payment of principal on or before its final maturity date of
December 31, 2036. The rating on the Class B Notes addresses the
ultimate payment of interest and principal on or before the legal
final maturity date. DBRS Morningstar does not rate the Class J
Notes.

At issuance, the Notes were backed by a EUR 480.0 million portfolio
by gross book value consisting of a mixed pool of Italian
nonperforming residential, commercial, and unsecured loans
originated by Banca Popolare di Bari S.c.p.A., Banca Tercas, and
Banca Caripe. All entities were subsequently merged into Banca
Popolare di Bari S.c.p.A. (BPB, or the originator).

The receivables are serviced by Prelios Credit Servicing S.p.A.
(the Servicer) while Securitization Services S.p.A. operates as
backup servicer.

RATING RATIONALE

The ratings downgrade follows a review of the transaction and is
based on the following analytical considerations:

-- Transaction performance: assessment of portfolio recoveries as
of May 31, 2021, focusing on: (1) a comparison between actual
collections and the Servicer's initial business plan forecast; (2)
the collection performance observed over the past months, including
the period following the outbreak of the Coronavirus Disease
(COVID-19); and (3) a comparison between the current performance
and DBRS Morningstar's expectations.

-- Portfolio characteristics: loan pool composition as of August
2021 and the evolution of its core features since issuance.

-- Transaction liquidating structure: the order of priority
entails a fully sequential amortization of the Notes (i.e., the
Class B Notes will begin to amortize following the full repayment
of the Class A Notes and the Class J Notes will amortize following
the repayment of the Class B Notes).

-- Performance ratios and underperformance events: as per the most
recent June 2021 payment report, the cumulative collection ratio
was 69% and the net present value cumulative profitability ratio
was 99%. Since the June 2020 interest payment date, the cumulative
collection ratio has breached the 90% limit, so that Class B Notes
interest payments are subordinated to the repayment of the Class A
Notes principal.

-- Liquidity support: the transaction benefits from an amortizing
cash reserve providing liquidity to the structure, covering
potential interest shortfall on the Class A Notes and senior costs.
The cash reserve target amount is equal to 3% of the Class A Notes
and Class B Notes principal outstanding and is currently fully
funded.

TRANSACTION AND PERFORMANCE

According to the latest investor report from June 2021, the
outstanding principal amounts of the Class A, Class B, and Class J
Notes were EUR 74.5 million, EUR 14.0 million, and EUR 10.0
million, respectively. The balance of the Class A Notes has
amortized by approximately 41.1% since issuance. The current
aggregated transaction balance is EUR 98.5 million.

As of May 2021, the transaction was performing significantly below
the Servicer's business plan expectations. The actual cumulative
gross collections equaled EUR 74.9 million whereas the Servicer's
initial business plan estimated cumulative gross collections of EUR
112.1 million for the same period. Therefore, as of May 2021, the
transaction was underperforming by EUR 37.2 million (-33.2%)
compared with the initial business plan expectations.

In the November 2020 annual review, DBRS Morningstar estimated
cumulative gross collections for the same period of EUR 96.1
million in the BB (sf) stress scenario and EUR 97.8 million in the
CCC (sf) stress scenario. Therefore, as of May 2021, the
transaction was performing below DBRS Morningstar's BB (sf) and CCC
(sf) stressed expectations at the November 2020 annual review.

In March 2021, the Servicer provided DBRS Morningstar with a
revised business plan, in which the Servicer assumed recoveries
below the initial expectations and over a longer time period. The
total cumulative gross collections from the updated business plan,
including actual gross collections of EUR 73.7 million as of
February 2021, result in a total of EUR 163.6 million, which is
17.0% lower than the total gross proceeds of EUR 197.2 million
estimated in the initial business plan. The Servicer has been
underperforming its updated business plan in the past quarters.

Excluding actual collections, the Servicer's expected future
collections from June 2021 now account for EUR 85.5 million, which
is less than the current aggregated outstanding balance of the
Class A and Class B Notes. In DBRS Morningstar's CCC (sf) scenario,
the Servicer's updated forecast was only adjusted in terms of
actual collections to date and timing of future expected
collections. Considering senior costs and interest due on the
Notes, the full repayment of Class A principal is increasingly
unlikely.

The final maturity date of the transaction is in December 2036.

DBRS Morningstar analyzed the transaction structure using Intex
DealMaker.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases to increases in unemployment rates and income reductions
for many borrowers. DBRS Morningstar anticipates that negative
effects may continue in the coming months for many nonperforming
loan (NPL) transactions. In particular, the deterioration of
macroeconomic conditions could negatively affect recoveries from
NPLs and the related real estate collaterals. The ratings are based
on additional analysis to expected performance as a result of the
global efforts to contain the spread of the coronavirus. For this
transaction, DBRS Morningstar incorporated its expectation of a
moderate medium-term decline in residential property prices, but
gave partial credit to house price increases from 2023 onward in
non-investment-grade scenarios.

Notes: All figures are in euros unless otherwise noted.




===================
M O N T E N E G R O
===================

KAP: Elektroprivreda Crne Gore Denies Rumor on Acquisition Bid
--------------------------------------------------------------
Radomir Ralev at SeeNews reports that Montenegro's state-controlled
power utility Elektroprivreda Crne Gore has never filed a bid for
the acquisition of aluminium producer KAP from local company
Uniprom, a senior EPCG manager said, denying local media
speculation about a potential transaction.

"We have never sent such an offer to anyone, neither to our
majority shareholder, the state, nor to Uniprom, nor to anyone
else," SeeNews quotes the CFO of EPCG, Miro Vracar, as saying in a
video file posted on the website of Montenegrin public broadcaster
RTCG on Dec. 2.

According to SeeNews, local media reported earlier on Dec 2 that
EPCG has expressed interest in the acquisition of KAP which is
planning to suspend production activities at its smelter in
Podgorica this month due to the high energy costs that the company
will incur after the expiry of its power supply contract with EPCG
on Jan. 1.

Uniprom said on Dec. 2 it is interested in a potential purchase of
KAP by EPCG and asked the state-controlled power utility to submit
a bid, SeeNews relates.

"We know for sure that KAP has losses of over EUR100 million
(US$113 million) per year, at today's prices.  We cannot take that
loss on our backs, because we would have to pass it on to citizens
who do not deserve this," Mr. Vracar, as cited by SeeNews, said.

KAP entered bankruptcy proceedings in 2013 and was sold by
Montenegro's government to Uniprom in 2014, SeeNews recounts.




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

RAVNAQ BANK: S&P Affirms 'B-/B' ICRs, Outlook Still Negative
------------------------------------------------------------
S&P Global Ratings affirmed its 'B-' long-term issuer credit rating
on Uzbekistan-based Ravnaq Bank (Ravnaq). The outlook remains
negative.

At the same time, S&P affirmed its 'B' short-term issuer credit
rating on the bank.

Ravnaq's low profitability and provisioning needs undermine its
capitalization. S&P siad, "We anticipate the bank will face
pressure from substantial loan loss provisions, stemming from its
low loan book quality and earnings, which are insufficient to cover
expected losses. As a result, we project Ravnaq will be loss-making
in 2021, and our risk-adjusted capital (RAC) ratio will decline to
8.0%-8.1%. We have therefore revised our capital and earnings
assessment to adequate from strong." The bank's profits will remain
volatile due to its small size, low operating efficiency, and
potential further losses related to the pandemic.

Ravnaq was hit harder by the COVID-19 pandemic than most of its
domestic peers but problem loans are gradually decreasing. Over the
past year, the bank had to restructure a substantial part of its
loan book, mainly driven by pandemic-related factors. This
increased pressure on credit losses and limited its business growth
prospects. Problem loans peaked at 37% of gross loans at Sept. 1,
2021, well-above the 6% average for the system. That said, S&P
notes the gradual recovery of the loan book, driven by the return
of some problem borrowers to normal payment schedules and limited
new problem loans this year. Therefore, S&P expects Ravnaq's
problem loans to decline to about 14%-16% of total loans in the
next 18 months, which is still higher than for most peers. The
bank's significant concentrations, with its 20 largest loans
comprising 64% of total loans at Oct. 1, 2021, exacerbate the risks
of sharp loan book deterioration.

Ravnaq's current liquidity buffers are sufficient to service its
needs, however, further delays in loan repayments could disrupt the
liquidity position. So far this year the bank's liquidity position
has been somewhat volatile, related to both unexpected delays in
inflows from loan repayments and its opportunistic liquidity
policy. The liquidity buffer stabilized in November 2021, following
several large problem loan repayments and new corporate deposits.
At Nov. 1, 2021, liquid assets comprised about 13% of total assets
and covered 32% of short-term liabilities, providing some cushion
for potential outflows. Negatively, we note relatively aggressive
liquidity management over the past few years, when the bank
operated with regulatory liquidity ratios close to minimum levels
to optimize funding costs. In S&P's view, any further disruption in
the flow of loan repayments might undermine the bank's liquidity
position. Therefore, it has revised the liquidity score to moderate
from adequate.

The negative outlook reflects the bank's still high amount of
problem loans, low earnings, and high loan concentrations. In
addition, it incorporates downside risks to the bank's liquidity
position.

S&P said, "We could lower the rating over the next six-to-12 months
if we see further asset quality deterioration or the liquidity
buffer weakens, for instance via unexpected high deposit outflows.

"An upgrade is a remote possibility, in our view. However, we might
revise the outlook to stable if Ravnaq's asset quality strengthens
and it maintains sufficient liquidity buffers with no rise in
deposit volatility."




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

GFG ALLIANCE: Making Great Progress in Recovery, Chairman Says
---------------------------------------------------------------
Erikka Askeland at The Press and Journal reports that Sanjeev
Gupta, chairman of the troubled GFG Alliance group, has claimed it
has made "great progress" repairing damage in the wake of the
collapse of its lender Greensill Capital.

Mr. Gupta, whose family owns the sprawling international group of
companies, said it has completed the first phase of a debt
restructuring in Australia and "injected fresh capital" into its UK
steel business, The Press and Journal relates.

According to The Press and Journal, in a statement, GFG insisted
its international businesses were achieving "excellent performance
which is bolstering cashflow and boosting the group's refinancing
efforts".

The group launched a restructuring committee in May after the
Serious Fraud Office announced it was investigating "suspected
fraud, fraudulent trading and money laundering" in relation to GFG
and Greensill, The Press and Journal recounts.

GFG, which also includes steel businesses in the UK and a stake in
a major tidal array in the Pentland Firth, bought the UK's last
aluminium smelter at Lochaber and adjacent hydroelectric plants in
2016 in a controversial deal that was underwritten by a GBP586
million Scottish government guarantee to buy energy from the hydro
plants, The Press and Journal discloses.

Under the latest stage of the restructuring, the firm hailed the
re-opening of a steel rod mill South Carolina but that its
aluminium plant in Witham, Essex will close with the loss of 64
jobs, The Press and Journal states.  It sold two further sites in
Coventry and Kidderminster to automotive supplier Evtec Aluminium
for GBP10 million, The Press and Journal relays.

The announcement follows a damning report into the governance of
the group published last month by the House of Commons Business,
Energy and Industrial Strategy (Beis) committee, The Press and
Journal notes.

According to The Press and Journal, the report titled "Liberty
Steel and the Future of the UK Steel Industry" commended business
secretary Kwasi Kwarteng's refusal to grant Liberty Steel a GBP170
million bail out and cast doubt on whether Mr. Gupta was a "fit and
proper person" to receive government support, unless he
restructured the group "into a more acceptable corporate structure
and publishes consolidated accounts that are adequately audited".


HELIOS DAC: DBRS Confirms B(high) Rating on Class E Notes
---------------------------------------------------------
DBRS Ratings Limited upgraded its ratings on the following classes
of Commercial Mortgage-Backed Floating Rate Notes due 2030 (the
Notes) issued by Helios (European Loan Conduit No. 37) DAC (the
Issuer):

-- Class A at AAA (sf)
-- Class B at A (high) (sf)
-- Class C at BBB (sf)

DBRS Morningstar also confirmed its ratings on the following
classes of Notes issued by the Issuer:

-- Class RFN at AAA (sf)
-- Class D at BB (high) (sf)
-- Class E at B (high) (sf)

The trend on Class RFN remains Stable and the trend on all other
classes remains Negative.

The rating confirmations and upgrades follow the borrower's partial
pre-payment of the loan, resulting in de-leveraging, the cash
contribution to cover future loan interest payments, and the
transaction's performance over the last 12 months.

Helios (European Loan Conduit No. 37) DAC is the securitization of
a single loan. The GBP 350 million senior loan matures on 12
December 2024 and the final Note maturity date is on May 2, 2030.
The loan is secured by a portfolio of 49 limited-service hotels
located across the United Kingdom. With the exception of the
Hampton by The Hilton in Liverpool and Park Inn hotel in York, the
portfolio comprises Holiday Inn Express Hotels.

The ultimate beneficial owner of the portfolio is London & Regional
Group (L&R), which acquired the hotels from Lone Star Funds in
2016. The hotels are managed by Atlas Hotels Group, which was also
acquired as part of the transaction in 2016 and is now a wholly
owned operating company of L&R.

Amid the Coronavirus Disease (COVID-19) pandemic, on the October
2020 interest payment date, the Debt Yield (DY) covenant was
breached and, as a consequence of not being cured, a transfer of
the loan into Special Servicing occurred on 23 November 2020.

In December 2020, the Operating Advisor was appointed by the
controlling class, Class E, and the Special Servicer requested an
updated valuation of the underlying properties portfolio. In
February 2021 , it was disclosed that the new value of the
portfolio provided by Cushman & Wakefield was, as of the January 5,
2021, GBP 472 million, nearly 16% less than initial valuation of
GBP 561 million. As a consequence, the LTV resulted in 73.6% in
excess of the covenant requirement of 72.4%.

The revenues from the underlying assets have remained dramatically
impacted in the first half of the 2021 with restriction
measurements imposed by the government first until May 2021 and
then further until July 2021. On 28 September 2021, the Special
Servicer and the Borrower agreed terms of amendments to the
facility agreement. In consideration for the waivers, the Borrower
deposited on the October 29, 2021 funds for a partial prepayment of
the loan by GBP 30 million and, separately deposited on the debt
service account an amount equal to GBP 13,500,315 to cover debt
service due on the January, April, July, and October 2022 interest
payment date. The principal waterfall is currently sequential and
the prepayment was applied for GBP 1,626,128 to the Class RFN notes
and for GBP 29,123,438 to the Class A notes, as of November 2021.

DBRS Morningstar maintained its net cash flow (NCF) assumption at
GBP 33 million as concluded at last year's surveillance review. In
addition, DBRS Morningstar maintained its cap rate at 8.9% which
translates into a DBRS Morningstar value of GBP 367.2 million,
representing a 22% haircut to the market value of GBP 472 million
provided by C&W, as of January 2021. The underwritten occupancy
rate is maintained at 73% across the portfolio as per last year's
review.

The transaction benefits from a liquidity reserve facility, which
was funded by the issuance of the Class RFN notes, and may be used
to cover shortfalls on the payment of interest due by the issuer to
the holders of the Class A to Class D notes. No drawings have been
made under the liquidity reserve facility since issuance. The
outstanding amount for the liquidity reserve is GBP 14,402,372 as
of November 2021.

The Class E notes have been accruing the deferral interest since
the February 2021 interest payment date with the ending balance of
GBP 14,600 as of November 2021. DBRS Morningstar's expectations is
that the Class E notes deferred interests will be repaid and DBRS
Morningstar therefore confirmed the rating on the Class E notes.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases to increases in unemployment rates and income reductions
for many tenants and borrowers. DBRS Morningstar anticipates that
vacancy rate increases and cash flow reductions may continue to
arise for many CMBS borrowers. In addition, commercial real estate
values could be negatively affected, at least in the short term,
affecting refinancing prospects for maturing loans and expected
recoveries for defaulted loans. The ratings are based on additional
analysis to expected performance as a result of the global efforts
to contain the spread of the coronavirus.

Notes: All figures are in British pound sterling unless otherwise
noted.


MCE INSURANCE: Bikers May Lose 10% of Claim Value
-------------------------------------------------
MCN has learned that bikers who were insured by the insolvent MCE
Insurance Company Ltd (MICL) will only have 90% of the value of the
claims paid by the Financial Compensation Services Scheme (FSCS).

Gibraltar based MICL were an underwriter that insured people
through the UK-based MCE Insurance Ltd (MIL), which is still
trading, MCN discloses.

On November 5, 2021 MICL were instructed to cease underwriting new
business, then on Nov. 19 the company was placed in administration,
MCN relates.  Once MICL went into administration the FSCS, which
operates a fund of last resort, became responsible paying any
claims, MCN notes.

However, under the FSCS standard terms of operation, first party
claimants are only protected to 90%, while third party claims are
100%, MCN states.

According to MCN, that means if you had a claim, such as a complete
write off or for theft, you'd lose 10% of the value of the claim,
on top of any compulsory or voluntary excess.


RIBBON FINANCE 2018: DBRS Confirms BB(low) Rating on Class F Notes
------------------------------------------------------------------
DBRS Ratings Limited confirmed its ratings on the following classes
of Commercial Mortgage-Backed Floating Rate Notes due 2028 issued
by Ribbon Finance 2018 Plc (the Issuer):

-- Class A at AAA (sf)
-- Class E at BB (high) (sf)
-- Class F at BB (low) (sf)

DBRS Morningstar also upgraded its ratings on the following
classes:

-- Class B at A (high) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (sf)

DBRS Morningstar also discontinued its rating on the following
class due to repayment:

-- Class G

All trends are Negative.

The rating confirmations and upgrades follow the borrower's equity
injection and the transaction's performance over the last 12
months.

Ribbon Finance 2018 Plc is the securitization of a GBP 449.8
million senior loan at issuance. The senior loan was advanced in
June 2018 to Ribbon Bidco Limited (the Borrower) to provide partial
acquisition financing for the Dayan family (the Sponsor) to acquire
Lapithus Hotels Management UK (LHM) and 20 hotels (the
Transaction). The initial lender is Goldman Sachs Bank USA and the
Transaction was arranged by Goldman Sachs International. Goldman
Sachs Bank USA also advanced a mezzanine loan of GBP 69.2 million
to Ribbon Mezzco Limited. The mezzanine loan, fully repaid on 27
July 2020, was structurally and contractually subordinated to the
senior loan and was not part of the Transaction. As of October
2021, the outstanding senior loan amount was GBP 283.8 million. The
expected maturity date is on April 13, 2023 with no extension
option available. The CMBS notes final maturity date is in April
2028, thereby the transaction benefits from a tail period of five
years.

The senior loan is secured by 19 hotels (20 originally) located in
the UK, three operate under the Crowne Plaza brand, 15 are flagged
by Holiday Inn, and one by Best Western (the Portfolio). In
February 2018, the initial valuer, HVS - London Office appraised
the total market value of the Portfolio at GBP 692 million,
subsequently, the value reduced to GBP 618 million in August 2019
following the sale of the Bloomsbury Hotel. In May 2021, Savills
re-valued the Portfolio at GBP 528.1 million showing a market value
decline of 14.5% when compared with the value in August 2019.

The loan interest is three-month Libor plus a 3.19% margin and the
interest payment date (IPD) falls quarterly on the 15th of January,
April, July, and October, together with the scheduled amortization
set at 1% per annum since origination.

On July 10, 2020, the facility agent agreed to waive any loan event
of default in connection with the Coronavirus Disease (COVID-19)
pandemic and the resultant temporary closure of certain Hotels, for
a period up to but excluding July 2021 IPD in return for an equity
cure payment. As such, the Sponsor deposited GBP 28 million into
the equity cure account. Subsequently, on April 10, 2021, a new
amendment and waiver letter was agreed, extending the current
waiver of the backward looking covenants (interest coverage ratio
and Debt Yield) until (but excluding) the July 2022 IPD. As part of
the amendment and waiver agreement, the borrower made a GBP 58
million mandatory loan prepayment on the April 2021 IPD, which was
allocated to the notes on a pro rata basis, whereas GBP 20 million
of funds was placed in a blocked account to sufficiently cover debt
service costs during the 12-month waiver period. Additionally, the
borrower agreed to a bi-annual valuation in order to closely
monitor the loan-to-value (LTV) ratio, and a further partial
paydown of the loan to maintain a level of LTV lower than 60%. The
Sponsor accordingly made a partial loan prepayment of GBP 20
million in July 2021 bringing the LTV to 49.88%.

In November 2020, DBRS Morningstar downgraded its ratings on
Classes B to G, in line with its coronavirus considerations and
macroeconomic scenarios for 2020-2022, where DBRS Morningstar
anticipated a longer period to a recovery resulting from lower
occupancy rates across the Portfolio and reduced cash flows.

Since the easing of coronavirus lockdown restrictions by the UK
Government in May 2021, the Portfolio performance metrics have
shown some improvement with reported occupancy at 79.06% (trailing
three months) versus an occupancy of 56.58% (trailing 12 months) as
of October 2021. As such, DBRS Morningstar maintained its
assumptions on occupancy of 63% across the Portfolio and net cash
flow (NCF) at GBP 31.5 million, as concluded at its last review of
the transaction. The cap rate was also maintained at 8.5%, which
translates to a DBRS Morningstar value of GBP 378.6 million,
representing a 28.3% haircut to the current market value of GBP
528.1 million.

The loan prepayment of GBP 78 million and consequently lower LTV,
when coupled with the borrowing entity's commitment to inject
equity to cover debt service until July 2022 has resulted in the
upgrade of the ratings on the Class B notes to A (high) (sf) from A
(sf), Class C notes to A (low) (sf) from BBB (high) (sf), and Class
D notes to (BBB) (sf) from BBB (low) (sf). The rating on the Class
G notes has been discontinued as the notes were redeemed in full,
following the reverse sequential application of the voluntary
prepayment in July 2021. DBRS Morningstar maintained its ratings on
the Class A notes at AAA (sf), Class E notes at BB (high) (sf), and
Class F notes at BB (low) (sf).

Although there has been a reported improvement in the take-up of
hotel rooms and hotel amenities, DBRS Morningstar maintains a
Negative trend on all classes of notes due to the uncertainty still
surrounding the hospitality sector caused by the coronavirus
pandemic.

The transaction benefits from a liquidity reserve facility, which
may be used to cover shortfalls on the payment of interest due by
the Issuer to the holders of the Class A to Class E notes. No
drawings have been made under the liquidity reserve facility since
issuance. The outstanding amount for the liquidity reserve is GBP
17,539,481 as of October 2021.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases to increases in unemployment rates and income reductions
for many tenants and borrowers. DBRS Morningstar anticipates that
vacancy rate increases and cash flow reductions may continue to
arise for many CMBS borrowers. In addition, commercial real estate
values could be negatively affected, at least in the short term,
affecting refinancing prospects for maturing loans and expected
recoveries for defaulted loans. The ratings are based on additional
analysis to expected performance as a result of the global efforts
to contain the spread of the coronavirus.

Notes: All figures are in British pound sterling unless otherwise
noted.


WESWAP: Bought Out of Administration by Blackthorn Finance
----------------------------------------------------------
Consultancy.uk reports that after becoming a victim of the global
collapse in travel, currency exchange firm WeSwap has been saved
from administration.

According to Consultancy.uk, the sale to rival Blackthorn Finance
Group was orchestrated by restructuring consultancy Opus.

Founded in 2014, WeSwap was an organization offering consumers
competitive exchange rates, when travelling abroad.

WeSwap won the Innovation in Travel Award and Best Travel Money
Provider at the British Bank Awards, and even counted tennis
champion Andy Murray and serial entrepreneur Alex Chesterman among
its backers.  However, when Covid-19 struck, WeSwap was hit
extremely hard by the lack of business and leisure travel during
the global pandemic, Consultancy.uk discloses.

Having been used by 500,000 people every year before the
coronavirus crisis, the London based company suffered a torrid 18
months, as it was stung by internal restrictions relating to
lockdown, Consultancy.uk relates.  Amid the pandemic, the start-up
slashed its costs by 40% in 2020, cutting its workforce by
one-fifth, however it was not enough to weather the storm,
Consultancy.uk notes.

Problems became increasingly pronounced, and in September 2021, UK
newspaper The Telegraph reported that a botched systems upgrade led
to money seemingly "disappearing" from holidaymakers' accounts,
Consultancy.uk relays.  The disappearances arose from WeSwap
looking to transfer cash to a new mobile app-based management
system, but a botched migration meant when it closed down its
online accounts on and cancelled all customers' cards, the transfer
did not occur, Consultancy.uk discloses.

Following months of hardship and mishap, WeSwap fell into
administration, with Allister Manson and Steven Parker of Opus
Restructuring & Insolvency as installed as joint administrators.
They have since secured a sale to rival Blackthorn Finance Group,
Consultancy.uk relates.  The pre-pack deal means customer service
has not been affected, while the firm's remaining jobs have been
preserved, Consultancy.uk states.

This pre-pack deal is expected to leave investors more than GBP20
million out of pocket, Consultancy.uk notes.


[*] DBRS Places Ratings of 6 UK RMBS Transactions Under Review
--------------------------------------------------------------
DBRS Ratings Limited placed the following ratings of six UK
residential mortgage-backed security (RMBS) transactions Under
Review with Positive Implications:

Towd Point Mortgage Funding 2019-Vantage2 Plc:
-- Class B notes rated AA (low) (sf)
-- Class C notes rated A (low) (sf)
-- Class D notes rated BBB (sf)
-- Class E notes rated BB (sf)
-- Class F notes rated B (sf)

The rating on the Class B notes issued by Towd Point Mortgage
Funding 2019-Vantage2 Plc addresses the ultimate payment of
interest and principal as well as the timely payment of interest
while the senior-most class outstanding. The ratings on the Class
C, Class D, Class E, and Class F notes address the ultimate payment
of interest and principal on or before the legal final maturity
date.

Towd Point Mortgage Funding 2019-Granite5 Plc:
-- Class B notes rated AA (sf)
-- Class C notes rated A (low) (sf)
-- Class D notes rated BBB (sf)
-- Class E notes rated BB (high) (sf)
-- Class F notes rated B (sf)

The rating on the Class B notes issued by Towd Point Mortgage
Funding 2019-Granite5 Plc addresses the ultimate payment of
interest and principal as well as the timely payment of interest
while the senior-most class outstanding. The ratings on the Class
C, Class D, Class E, and Class F notes address the ultimate payment
of interest and principal on or before the legal final maturity
date.

Finsbury Square 2019-1 plc:
-- Class B Notes rated AA (sf)
-- Class C Notes rated A (low) (sf)
-- Class D Notes rated BBB (sf)
-- Class E Notes rated BB (high) (sf)

The ratings on the Class B, Class C, Class D, and Class E Notes
issued by Finsbury Square 2019-1 plc address the timely payment of
interest and principal on or before the legal final maturity date.

Finsbury Square 2019-2 plc:
-- Class B notes rated AA (high) (sf)
-- Class C notes rated A (high) (sf)
-- Class D notes rated BBB (high) (sf)
-- Class E notes rated BB (high) (sf)

The ratings on the Class B, Class C, Class D, and Class E notes
issued by Finsbury Square 2019-2 plc address the ultimate payment
of interest and principal as well as the timely payment of interest
while the senior-most class outstanding.

Finsbury Square 2019-3 plc:
-- Class B Notes rated AA (high) (sf)
-- Class C Notes rated A (sf)
-- Class D Notes rated BBB (high) (sf)
-- Class E Notes rated BBB (low) (sf)
-- Class X Notes rated AA (sf)

The ratings on the Class B, Class C, Class D, and Class E Notes
issued by Finsbury Square 2019-3 plc address the ultimate payment
of interest and principal as well as the timely payment of interest
while the senior-most class outstanding. The rating on the Class X
Notes addresses the ultimate payment of interest and principal on
or before the legal final maturity date.

Finsbury Square 2020-1 plc:
-- Class B Notes rated AA (high) (sf)
-- Class C Notes rated A (high) (sf)
-- Class D Notes rated BBB (high) (sf)
-- Class X Notes rated BB (high) (sf)

The ratings on the Class B, Class C, and Class D Notes issued by
Finsbury Square 2020-1 plc address the ultimate payment of interest
and principal as well as the timely payment of interest while the
senior-most class outstanding. The rating on the Class X Notes
addresses the ultimate payment of interest and principal on or
before the legal final maturity date.

DBRS Morningstar also rates the Class A notes issued in each
transaction at AAA (sf), but did not place these classes Under
Review with Positive Implications.

KEY RATING DRIVERS AND CONSIDERATIONS

On October 27, 2021, DBRS Morningstar finalized its updated
"European RMBS Insight: UK Addendum" (the Methodology), superseding
the prior version published on October 9, 2020. The Methodology
presents the criteria for which UK RMBS ratings and, where
relevant, UK covered bonds ratings, are assigned and/or monitored.

The changes to the Methodology include revisions to the loan
scoring approach, delinquency migration matrices, and loss given
default floors, as well as updates to house price indexation and
market value decline rates through the first quarter of 2020.

As a consequence, DBRS Morningstar placed the aforementioned
tranches Under Review with Positive Implications as DBRS
Morningstar considers these classes to be more affected by the
changes to the Methodology.

These ratings are Under Review. Generally, the conditions that lead
to the assignment of ratings Under Review are resolved within a
90-day period. Further information on potential rating sensitivity
as a result of this methodological change will be available when
DBRS Morningstar resolves the Under Review status on the affected
classes.

The Coronavirus Disease (COVID-19) and the resulting isolation
measures have caused an immediate economic contraction, leading in
some cases to increases in unemployment rates and income reductions
for many borrowers. DBRS Morningstar anticipates that delinquencies
may continue to increase in the coming months for many structured
finance transactions. The ratings are based on additional analysis
to expected performance as a result of the global efforts to
contain the spread of the coronavirus.

Notes: All figures are in British pound sterling unless otherwise
noted.



                           *********


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

Troubled Company Reporter-Europe is a daily newsletter co-
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