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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

          Friday, December 10, 2021, Vol. 22, No. 241

                           Headlines



B E L A R U S

BELARUSBANK: S&P Affirms 'B/B' Isuer Credit Ratings, Outlook Neg.


B O S N I A   A N D   H E R Z E G O V I N A

NAPCO BEDS: Kavgico Eyes Acquisition of Former Bed Factory
NOVI ZITOPROMET: Croatian Businessman Buys Cereal Business


F R A N C E

NOVAFIVES SAS: Moody's Affirms Caa1 CFR & Alters Outlook to Stable
RENAULT SA: DBRS Confirms BB(high) Issuer Rating


G E O R G I A

GEORGIAN RAILWAY: S&P Affirms B+/B Ratings, Outlook Now Stable


G E R M A N Y

FRESHWORLD HOLDING III: Moody's Affirms 'B2' CFR, Outlook Stable
FRESHWORLD HOLDING: Fitch Raises LT IDR to 'B+', Outlook Stable
MEDIAN BV: Fitch Assigns Final 'B' LT IDR, Outlook Stable
STANDARD PROFIL: Moody's Affirms B3 CFR, Alters Outlook to Neg.


I R E L A N D

FROST CMBS 2021-1: DBRS Gives Prov. BB(high) Rating on E Notes
INVESCO EURO: Fitch Affirms B- Rating on 4 Note Classes
JUBILEE 2021-XXV: Fitch Rates Class F Notes Final 'B-'
JUBILEE CLO 2021-XXV: Moody's Assigns B3 Rating to Class F Notes
MADISON PARK XIV: Fitch Rates Class F-R Notes 'B-(EXP)'

MADISON PARK XIV: Moody's Gives (P)B3 Rating to EUR15.4MM F Notes
MILLTOWN PARK: Fitch Raises Class E Notes to 'B+'
PENTA CLO 8: Moody's Assigns B3 Rating to EUR11.4MM Class F Notes
PENTA CLO 8: S&P Assigns B- (sf) Rating to Class F-R Notes
ROS AOIBHINN: Enters Liquidation, Now Under HSE Stewardship



I T A L Y

BANCA POPOLARE: DBRS Assigns BB Subordinated Debt Rating
ICCREA BANCA: DBRS Confirms BB(high) LongTerm Issuer Rating
IGD SIIQ: S&P Alters Outlook to Stable, Affirms 'BB+' Ratings
MAGGESE SRL: DBRS Lowers Class A Notes Rating to CCC(high)
ROSSINI SARL: Moody's Affirms 'B2' CFR on EUSA Pharma Transaction



M O N T E N E G R O

KAP: Uniprom to Gradually Close Down Aluminium Smelter


N E T H E R L A N D S

E-MAC 2004-II: Fitch Affirms CCC Rating on Class E Tranche
WP/AP TELECOM IV: Moody's Rates New EUR800MM Sr. Secured Notes 'B1'


P O L A N D

ALIOR BANK: Fitch Affirms 'BB' LT IDR, Alters Outlook to Stable


S W I T Z E R L A N D

ARCHROMA HOLDINGS: Moody's Hikes CFR to B2, Outlook Remains Stable


T U R K E Y

ISTANBUL METROPOLITAN: Moody's Affirms B2 Long Term Issuer Rating
ULKER BISKUVI: Fitch Lowers LT FC IDR to 'B+', Outlook Negative


U N I T E D   K I N G D O M

ALHAMBRA: Goes Into Receivership, Building Up for Sale
NATIONAL BANK: Fitch Affirms Then Withdraws 'B+' LT IDR


X X X X X X X X

[*] BOOK REVIEW: Hospitals, Health and People

                           - - - - -


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B E L A R U S
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BELARUSBANK: S&P Affirms 'B/B' Isuer Credit Ratings, Outlook Neg.
-----------------------------------------------------------------
S&P Global Ratings affirmed its 'B/B' long- and short-term issuer
credit ratings on three Belarus-based financial
institutions--Belarusbank, Belagroprombank JSC, and Bank BelVEB
OJSC. The outlooks on all three banks remain negative.

S&P said, "We believe that deposit outflows observed in
August-December 2020 have subsided over 2021. Over the first 10
months of 2021 the deposit base has stabilized--Belarusbank, which
holds 40% of total system deposits and Belagroprombank, which holds
15%, reported 5.5% and 11.4% deposit growth respectively. Although
large outflows were observed in retail foreign-currency-denominated
deposits, this was mitigated by corporate deposit inflows both in
national and foreign currency. In our view, banks' liquidity
remains under control due to limited growth in new lending. We
believe that some deposit outflows might continue in 2022 but we
expect these will remain manageable."

In contrast, Bank BelVEB, which holds a much lower 4.3% of total
deposits, saw an outflow of about 12% over the first nine months of
2021, primarily driven by negative dynamics in the retail segment.
However, since Bank BelVEB's share of retail deposits is moderate
and given the availability of several liquidity lines from parent
VEB.RF, S&P doesn't see immediate liquidity risks.

S&P said, "All three banks significantly limited new lending in
2021 and we expect nominal lending growth of up to 5% in 2022.
Although individual loans to finance projects for strategically
important companies are possible, we understand that generally new
lending is limited so far.

"We have observed some improvement in Belarusian banking system
asset quality as of June 30, 2021.Problem assets (Stage 3 and
purchased or originated credit-impaired [POCI] loans) decreased to
12% of total loans during the period compared with 13.2% in 2020.
The economy performed better than we anticipated in 2021, with real
GDP growth of 2.7% for the first nine months of the year. That
said, we note that there could be some delayed effects from
sanctions and potential deterioration of the macroeconomic
environment in 2022.

"We believe the impact of sanctions will be manageable for
Belarusbank and Belagroprombank.This is given the banks' low
dependence on EU and U.S. wholesale funding and their moderate loan
book exposure to sanctioned corporate entities. Bank BelVEB is not
subject to the sanctions imposed on Belarus and we consider its
exposure to affected Belarusian corporate borrowers very modest."

Belarusbank

S&P considers Belarusbank, which is the country's largest bank and
state owned, a government-related entity (GRE) with a moderately
high likelihood of receiving extraordinary support from the
Belarusian government. Its ratings reflect the bank's high
dependence on economic conditions in Belarus, its reliance on
ongoing and extraordinary capital and liquidity support from the
state, and substantial lending to and funding from government
bodies and state-owned enterprises.

Belarusbank's superior business position in its domestic market
remains a rating strength versus domestic peers. The bank has the
most diverse business profile in Belarus and a market share
exceeding 40% of total assets, total loans, and customer deposits.
S&P believes that Belarusbank's ability to demonstrate resilient
financial performance during the current period of economic
turbulence will be very important for it to maintain its superior
business position in the medium term.

S&P said, "The 'B' long-term rating on Belarusbank is one notch
lower than our 'b+' stand-alone credit profile (SACP) assessment,
because we view the sovereign's creditworthiness as the main
ratings constraint. The bank's state ownership makes it strongly
dependent on the Belarusian government's fiscal position."
Furthermore, the bank operates exclusively in Belarus and remains
highly exposed to country risk.

Outlook

S&P's negative outlook on Belarusbank mirrors that on the
sovereign.

Downside scenario: A negative rating action on Belarus would
trigger a similar action on the bank.

Upside scenario: S&P could revise the outlook to stable should it
revises the outlook on the sovereign to stable.

Belagroprombank JSC

S&P said, "We consider Belagroprombank, which is the country's
second largest bank and state owned, a GRE with a moderately high
likelihood of receiving extraordinary support from the Belarusian
government. Our ratings reflect the bank's high dependence on
economic conditions in Belarus, its reliance on ongoing and
extraordinary capital and liquidity support from the state, and
substantial lending to and funding from government bodies and
state-owned enterprises."

Belagroprombank's asset quality appears to be somewhat weaker than
the banking sector average. However, the risk that its metrics will
deteriorate further, materially above the projected systemwide
average for Stage 3 and POCI loans (15%-16%), is mitigated by its
focus on the agricultural sector, which has shown fairly resilient
performance during the pandemic. Notably, during first-half 2021
Belagroprombank's share of Stage 3 and POCI loans didn't increase.
Moreover, the bank's coverage of Stage 2, Stage 3, and POCI loans
by reserves was 19% as of June 30, 2021, which is comparable with
the system average.

Balancing those factors with the bank' relatively weak
capitalization in a global context, S&P assesses the SACP at 'b'.

Outlook

S&P's negative outlook on Belagroprombank mirrors that on Belarus
and reflects pressure on its asset quality over the next 12
months.

Downside scenario: A negative rating action on Belarus would
trigger a similar action on the bank. S&P could also take a
negative rating action if the bank's credit fundamentals
deteriorate significantly. This could happen if asset quality
noticeably weakens below the system average, resulting in a
material increase in credit costs and new provisions not offset by
corresponding capital injections to mitigate the eventual impact.

Upside scenario: S&P could revise the outlook to stable if it
revises the outlook on the sovereign rating to stable, combined
with Belagroprombank achieving asset quality close to the system
average, while maintaining sufficient liquidity buffers.

Bank BelVEB OJSC

S&P said, "We consider Bank BelVEB a strategically important
subsidiary of Russia's VEB.RF (BBB-/Stable/A-3). This means we
expect that the Russian parent will continue providing financial
and operational support. Although the bank's liquidity profile
benefits from ongoing parental support, we believe that it cannot
fully mitigate the high risks of operating in Belarus. We therefore
cap the ratings on Bank BelVEB at the level of our foreign currency
sovereign credit ratings on Belarus (B/Negative/B).

"In our view, Bank BelVEB's SACP, which we see at 'b', also
benefits from its more flexible business model compared with
state-owned Belarusian peers.

"We have revised our assessment of Bank BelVEB's capital and
earnings to moderate from weak. Under our updated projections, we
expect an S&P Global Ratings risk-adjusted capital (RAC) ratio
consistently above 5% over the forecast horizon. We now believe
that Bank BelVEB's loan portfolio growth will be negative in 2021
and its provision needs will be somewhat lower than our previous
expectations and compare well with those of peers."

Outlook

S&P's negative outlook on Bank BelVEB mirrors that on Belarus. A
deterioration of Bank BelVEB's credit fundamentals won't
automatically lead to a downgrade because its rating could
incorporate up to three notches of uplift for parental support.

Downside scenario: A negative rating action on Belarus would
trigger a similar action on the bank.

Upside scenario: S&P could revise the outlook to stable should it
revises the outlook on the sovereign to stable.

Ratings Score Snapshot

  Belarusbank

  Issuer Credit Ratings    B/Negative/B
  SACP                     b+
  Anchor                   b
  Business Position        Strong (+1)
  Capital & Earnings       Weak (0)
  Risk Position            Adequate (0)
  Funding and Liquidity    Average and Adequate (0)
  Support                  0
  ALAC Support             0
  GRE Support              0
  Group Support            0
  Sovereign Support        0
  Additional factors       (-1)

  Belagroprombank JSC

  Issuer Credit Ratings    B/Negative/B
  SACP                     
  Anchor                   b
  Business Position        Adequate (0)
  Capital & Earnings       Weak (0)
  Risk Position            Adequate (0)
  Funding and Liquidity    Average and Adequate (0)
  Support                  0
  ALAC Support             0
  GRE Support              0
  Group Support            
  Sovereign Support        0
  Additional factors       0

  Bank BelVEB OJSC
                           TO            FROM
  Issuer Credit Ratings    B/Negative/B  B/Negative/B
  SACP                     b             b
  Anchor                   b             b
  Business Position        Adequate (0)  Adequate (0)
  Capital & Earnings       Moderate (0)  Weak (0)
  Risk Position            Adequate (0)  Adequate (0)
  Funding and Liquidity    Average and   Average and
                           Adequate (0)  Adequate (0)
  Support                  0             0
  ALAC Support             0             0
  GRE Support              0             0
  Group Support
  Sovereign Support        0             0
  Additional factors       0             0

  Ratings List

  RATINGS AFFIRMED

  BELAGROPROMBANK JSC
  
   Issuer Credit Rating    B/Negative/B

  RATINGS AFFIRMED

  BELARUSBANK

   Issuer Credit Rating    B/Negative/B

  RATINGS AFFIRMED

  BANK BELVEB OJSC

   Issuer Credit Rating    B/Negative/B




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B O S N I A   A N D   H E R Z E G O V I N A
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NAPCO BEDS: Kavgico Eyes Acquisition of Former Bed Factory
----------------------------------------------------------
Dragana Petrushevska at SeeNews reports that Bosnian furniture
manufacturer Kavgico is interested in buying the former bed factory
Napco owned by Dutch-based Napco Beds in the northern municipality
of Petrovo, the municipal government said.

According to SeeNews, the municipal government of Petrovo said in a
statement earlier this week Kavgico is looking to buy the facility
by the end of 2021 with a view to launching production of
box-spring beds there in April 2022.

The new factory would employ about 100 people, SeeNews discloses.

Napco Beds closed its factory in Petrovo in 2018 after declaring
bankruptcy, SeeNews relays, citing local media reports.



NOVI ZITOPROMET: Croatian Businessman Buys Cereal Business
----------------------------------------------------------
Annie Tsoneva at SeeNews reports that Croatian businessman Enver
Moralic said he agreed to buy Bosnian cereals processor Novi
Zitopromet, Bosnian media reported.

According to SeeNews, Mr. Moralic told daily Nezavisne Novine on
Nov. 23 "We have agreed the purchase and paid the bigger part of
the price, we are still waiting to coordinate some other details
but more or less everything has been agreed."

He did not elaborate on the price but the same daily reported on
Nov. 22 that the price is between EUR3.5 million (US$3.9 million)
and EUR4.0 million, SeeNews notes.

So far, the company's owner was Bosnian company Pavgord, which
bought its immovable property for BAM3.1 million (US$1.8
million/EUR1.6 million) in January, SeeNews recounts.

Earlier, Mr. Pavgord bought the equipment of the milling company
and paid BAM600,000 as social contributions for its employees,
according to SeeNews.

The company, previously named Zitopromet, had 113 employees before
it went into bankruptcy in December 2019, SeeNews relates.

Mr. Moralic has pledged to retain the company's cereals processing
business and will keep most of its employees, SeeNews states.




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F R A N C E
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NOVAFIVES SAS: Moody's Affirms Caa1 CFR & Alters Outlook to Stable
------------------------------------------------------------------
Moody's Investors Service affirmed the Caa1 corporate family rating
and Caa1-PD probability of default rating of Novafives S.A.S.
Concurrently, Moody's affirmed the Caa2 instrument ratings of
EUR325 million fixed-rate senior secured notes and EUR275 million
floating-rate senior secured notes both maturing 2025. The outlook
was changed to stable from negative.

RATINGS RATIONALE

The stabilization of the outlook and ratings affirmation reflects
gradual recovery in Novafives' operating and financial performance,
including a reduction in Moody's-adjusted leverage and positive
free cash flow (FCF) generation over the last several quarters on
the back of strong demand from some of its end markets, as well as
profitability close to 2019 levels. The rating action also takes
into consideration the agency's expectation that over the next
12-18 months Novafives will sustain its recently recovered
profitability and continue to expand its EBITDA supported by
improved stability in its end markets, resulting in leverage
reduction to below 10x Moody's-adjusted debt/EBITDA, albeit still
high.

As of end-September 2021, Novafives' Moody's-adjusted leverage
decreased more than two-fold to 11.4x from 24x as of end-2020 (or
11.6x and around 18x excluding unrealized foreign exchange losses
on intercompany loans, respectively) as a result of EBITDA
expansion. After hitting a trough in Q2 2020 with company-adjusted
EBITDA at breakeven, Novafives' EBITDA rose 67% year-on-year growth
in the first nine months of 2021 compared to the same period in the
prior year but remains about 20% short of its earnings in the same
period of 2019. The increase in the topline was moderate at 9% as
order execution was constrained by travel restrictions in H1 2021
and later by supply chain constraints, such as component shortages
and logistical slowdowns. At the same time, the company was able to
restore its profit margins largely back to 2019 levels despite
inflationary pressure, particularly from the raw materials price
increase. The executed order backlog carried higher gross profit
margins and the increased topline improved fixed costs absorption,
supported by previous restructuring initiatives. As the majority of
the executed orders were of small or medium size, which have
relatively short lead times, Novafives was able to passthrough the
cost inflation to its customers. In the first nine months of 2021,
the company's FCF turned positive following higher earnings and
significant working capital release.

Over the next 12-18 months, the rating agency expects Novafives to
continue deleveraging to below 10.0x Moody's-adjusted debt/EBITDA
with the combination of EBITDA expansion and debt reduction as the
French-state-guaranteed loan starts amortizing in July 2022.
Against the company's guidance for EBITDA recovery back to 2019
levels and positive FCF, Moody's conservatively forecasts only
modest growth in Moody's-adjusted EBITDA of about 5%-8% compared
with EUR95 million in the 12 months that ended September 30, 2021,
which assumes the recent profitability recovery remains in place,
somewhat offset by potential challenges in order execution such as
ongoing travel restrictions to some countries and likely continued
stretch in the global supply chains. The agency forecasts that the
company's FCF (as adjusted by Moody's) will be moderately negative
compared to deeply negative EUR89 million in 2020, which will be
mostly driven by working capital consumption on higher economic
activity compared to 2020 from one side and potential further
supply chain constraints from the other. The agency notes that
working capital developments depend on the backlog split between
the three business divisions, with Process Technologies having
structural benefits with higher prepayments from customers and
longer execution timeline. Also, large orders usually come with
material down payments and progress payments that can potentially
offset working capital consumption by growing business activity in
the other two divisions, however, the receipt of such large orders
is yet to be seen.

The Caa1 rating is constrained by the company's still high
Moody's-adjusted leverage, its low profitability compared to
manufacturing peers, though typical for engineering companies,
historically volatile working capital that strained the company's
FCF generation and amortization of the French-state-guaranteed loan
starting from July 2022, which while positive in terms of debt
reduction will nevertheless weigh on its liquidity.

At the same time, Novafives' CFR is supported by the company's good
geographical diversification and leading niche market positions and
products with high technological content; long-standing customer
relationships, which create a barrier to entry for potential
competitors; and its sizeable order backlog of around EUR1.5
billion as of September 2021 and potential for strong demand for
engineering solutions in the Process Technologies and Smart
Automation divisions.

LIQUIDITY

Novafives' liquidity is adequate, which is primarily supported by
the company's large cash on balance. As of September 30, 2021, the
company had around EUR226 million of cash, which together with
expected funds from operations of over EUR45 million from Q4 2021
through the end of 2022, will be sufficient to accommodate the
company's cash needs for the next five quarters (October 2021 -
December 2022), including seasonal working capital swings, planned
capital spending of around EUR54 million (including lease principal
payments), and upcoming debt maturities of a little under EUR70
million, including repayment of the first installment of EUR40
million under the EUR200 million French-State-guaranteed loan in
July 2022. No significant debt repayments are due until June 2025,
when the notes issued in April 2018 become due.

The agency notes that Novafives has a EUR115 million committed
long-term revolving credit facility (RCF) due 2024, which is
currently drawn at EUR48 million. However, further drawings are
limited to just EUR2 million as only an initial EUR50 million layer
out of total EUR115 million is available without any leverage
condition. The excess (EUR65 million) is available subject to a
leverage ratio test below 6.0x at the end of the previous quarter.
As of September 30, 2021, RCF-defined net leverage was 7.1x,
restricting the company's access to additional liquidity. Under
Moody's forecast Novafives' net leverage will remain above the test
level of 6.0x through the end of 2022. As a result, the company's
ability to keep working capital consumption to a minimum is key to
maintaining its adequate liquidity.

RATIONALE FOR THE STABLE OUTLOOK

The stable outlook reflects Moody's expectation that over the next
12-18 months Novafives will be able to translate its solid order
backlog into revenue and maintain its recently restored profit
margins, which will result in further modest reduction in leverage,
albeit it will remain high, and the company will maintain its
adequate liquidity.

STRUCTURAL CONSIDERATIONS

Novafives S.A.S. is the top company in the restricted group and the
reporting entity for the consolidated group. The EUR325 million
fixed-rate senior secured notes and EUR275 floating-rate senior
secured notes are secured by share pledges over shares of Fives
S.A.S., the main operating company, the issuer's bank accounts and
intercompany receivables. The EUR115 million super senior RCF is
borrowed by Novafives S.A.S. and Fives S.A.S. The RCF ranks pari
passu with all existing and future senior secured debt and shares
the same collateral package, but benefits from a priority claim in
an enforcement scenario. The Caa2 instrument rating on the senior
notes, one notch below the CFR, reflects the fact that in an
enforcement scenario they would rank behind the RCF.

The EUR200 million loan is placed at the level of Fives S.A.S. The
loan benefits from a 90% guarantee from the French State. Apart
from that it is unsecured. Structurally it is in an advanced
position over the EUR325 million fixed-rate senior secured notes
and EUR275 floating-rate senior secured notes, for which Fives
S.A.S. has also acceded as a guarantor, but ranks below the EUR115
million RCF.

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

The ratings could be upgraded with evidence of Moody's-adjusted
EBITA margin rising to around 5%, Moody's-adjusted debt/EBITDA
falling below 7.5x, and at least modestly positive FCF, as well as
expectations for the company to sustain these improved metrics. A
higher rating would also require maintenance of an adequate
liquidity position, including comfortable covenant headroom.

Moody's could downgrade the ratings if the company's FCF is
negative for a prolonged period of time or its liquidity
deteriorates in any other way, or if it is unable to reduce its
Moody's-adjusted leverage from current very high levels.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Manufacturing
published in September 2021.

COMPANY PROFILE

Novafives S.A.S. is a global industrial engineering group. The
company designs machines, process equipment and production lines
for use in a number of different industries including automotive,
logistics (for e-commerce, courier and retail), steel, aluminum,
energy, cement, and aerospace sectors. As of September 30, 2021,
Novafives employed approximately 8,400 people and had a network of
over 100 operational units in nearly 30 countries. In the 12 months
that ended September 30, 2021, the company generated sales of
around EUR1.7 billion and company-adjusted EBITDA of around EUR105
million.

RENAULT SA: DBRS Confirms BB(high) Issuer Rating
------------------------------------------------
DBRS Limited confirmed the Issuer Rating of Renault S.A. (Renault
or the Company) at BB (high). The confirmation reflects the
Company's moderately improving operating performance (albeit from
weak levels) amid initial progress on its current strategic plan
(designated as Renaulution by the Company) which, in combination
with Renault's conservative financial policy, has prevented a
further deterioration in its financial risk assessment to a level
that would warrant a downgrade. The trend on the rating remains
Negative, however, as Renault's operating performance (notably that
of the automotive operations) remains lacklustre, with the ongoing
global semiconductor shortage and rising raw material costs
representing meaningful headwinds over the near term.

While the Company's earnings in 2020 were markedly weaker year over
year, DBRS Morningstar notes that this primarily reflects sizable
losses incurred in the first half of the year in which automotive
(among other sectors) industry conditions were extremely
unfavorable substantially because of the global progression of the
Coronavirus Disease (COVID-19), adversely affecting both demand and
production levels. However, benefitting from an industry recovery
over the remainder of the year that exceeded DBRS Morningstar's
expectations, Renault reverted to modest profitability in H2 2020.
Moreover, Renault's automotive operations are estimated to remain
nominally profitable in 2021 amid volume gains (notwithstanding
production losses of close to an estimated 500,000 units as a
result of the semiconductor shortage), firmer product mix and
higher pricing. The Company is also on track to attain fixed cost
reductions of approximately EUR 2 billion targeted in its
Renaulution plan one year ahead of schedule. DBRS Morningstar
notes, however, that Renault's profitability remains low relative
to its automotive peers. Moreover, increasing raw material and
product development costs appear likely to undermine margin gains
going forward as Renault has limited pricing power to help offset
such increases.

Despite notably weaker earnings and operating cash flow in recent
years, Renault's liquidity remains sound, partly reflecting
implemented cost reductions, curtailed capital expenditures, and
the current cancellation of ordinary dividends. The Company also
drew down approximately EUR 4 billion last year from its bank
credit facility (90%) guaranteed by the French State, (with EUR 1
billion slated for repayment this year). As of June 30, 2021, the
liquidity position of the Company's automotive segment amounted to
EUR 16.7 billion (consisting of EUR 13.3 billion in cash balances
and EUR 3.4 billion in available committed credit lines). This is
deemed sufficient by DBRS Morningstar to readily absorb near-term
debt maturities in addition to ongoing negative free cash flow
generation (that is nonetheless estimated by DBRS Morningstar to
moderate considerably going forward).

Consistent with the Negative trend on the rating, increasing losses
at Renault in the forthcoming periods would likely result in a
downgrade. Conversely, markedly stronger operating performance over
a similar time horizon could have positive rating implications;
DBRS Morningstar notes, however, that such improvement stands to be
hindered by significant cost headwinds (notably in the form of
ongoing investments associated with the increasing electrification
of the automotive fleet) facing the industry. Finally, despite
recent associated challenges, Renault's ratings continue to benefit
from its alliance (substantially) with Nissan Motor Co., Ltd.
(rated BBB (low) with a Negative trend by DBRS Morningstar);
accordingly, any meaningful unwinding thereof could also result in
negative rating implications.

Notes: All figures are in euros unless otherwise noted.




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G E O R G I A
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GEORGIAN RAILWAY: S&P Affirms B+/B Ratings, Outlook Now Stable
--------------------------------------------------------------
S&P Global Ratings revised its outlook on Georgian Railway JSC to
stable from negative and affirmed its 'B+/B' ratings on the company
and 'B+' rating on its bond.

The stable outlook reflects that pressure from the potential
downgrade of Georgia will likely be offset by Georgian Railway's
strengthening performance, namely with FFO to debt exceeding 8%
from 2022.

Recent refinancing of $500 million of notes has eliminated
short-to-medium-term refinancing risk and improved credit metrics.
In June 2021, Georgian Railway successfully refinanced its $500
million (about Gergian lari [GEL] 1.6 billion) notes due in July
2022 with a new $500 million green bond due in 2028 at better terms
and conditions. With a 4% coupon on the new bond compared with
7.75% on the notes, the company's interest expense reduced by half
from the second half of 2021, from GEL120 million-GEL130 million to
GEL65 million-GEL70 million, annualized. This supports the
company's cash flow and credit metrics because the total debt
portfolio remained unchanged. The lower coupon on the new bond
strengthens FFO to debt by about 3% annually, all else being
unchanged, although we'll see the full-year impact only from 2022.
Georgian Railway paid about GEL140 million of issuance costs and
premium for early redemption from available cash, with no need for
additional borrowings. This is a one-off expense in substance, but
is included in finance costs for 2021, so this year's numbers does
not represent future interest expense. Therefore, S&P forecasts FFO
will be close to zero in 2021, recovering to GEL140 million-GEL160
million in 2022, which will result in FFO to debt of 8%-10% in its
base case compared with 5% in 2020.

S&P said, "We forecast debt to EBITDA to recover to 7.5x-8.1x from
2021, supported by moderate growth of freight volumes, which were
not materially hit by the pandemic. Despite the pandemic, operating
performance in the core freight segment has been improving
recently. For the first nine months of 2021, freight turnover
increased by 15% to 2,455 million tons per kilometer compared with
the same period in 2020, and we expect 2021 revenue will increase
by 13%-15% year on year. This, together with a stronger lari
expected will translate into debt to EBITDA of 7.5x-8.0x in 2021
and likely below 8.0x in 2022 versus 8.7x in 2020. The growth of
freight was due to an increase in oil products transported during
2021, mainly from Azerbaijan and Turkmenistan. We expect the total
volume of oil products will increase to about 3.8 million tons in
2021 and stabilize at about 3.5 million tons in 2022, compared with
about 3 million tons in 2020. We forecast that improving operating
performance and cautious cost management will likely translate into
stronger metrics, with FFO to debt exceeding 8% in 2022-2023, which
we consider commensurate with a stand-alone credit profile of 'b',
one notch higher than the current 'b-'. Still, the recovery in
metrics will depend on the company's ability to further bolster its
revenue and control costs, as well as the trajectory of foreign
exchange rates."

Georgian Railway is resuming capital investments after
pandemic-related cuts in 2020, but it won't need additional
borrowings to fund them. Despite material capital expenditure
(capex) plans, S&P expects the company will maintain positive free
operating cash flow (FOCF) from 2022 onward. In 2021, capex will
likely have reached prepandemic levels of GEL100 million-GEL110
million, which is well above the GEL56 million spent in 2020.
Georgian Railway's investment plans are aimed at replacing old
rolling stock and completing a modernization project to increase
capacity to 48 million tons a year from 27 million tons. Current
utilization is materially lower, at about 11 million tons in 2020,
but the modernization project is close to completion (93% at
year-end 2020) and management expects the railway will offer
shippers better terms, which will increase cash flows. Georgian
Railway invested almost GEL0.9 billion in the modernization project
over 2010-2020.

The negative outlook on the sovereign rating constraint the rating
on Georgian Railway. The negative outlook on Georgia
(BB/Negative/B) reflects risks to the country's ability to generate
adequate foreign currency earnings to service its sizable external
liabilities over 2021-2024. Given that S&P's rating on Georgian
Railway factors in two notches of uplift for extraordinary
government support, the potential downside for the sovereign rating
somewhat limits upside ratings prospects for the company, despite
an expected recovery of its credit metrics. Georgian Railway is one
of the largest corporate borrowers in Georgia and an important
infrastructure link in the country and the region. S&P considers
that the government has a strong incentive to support Georgian
Railway because, if it were to default, there would be considerable
damage to the sovereign's reputation and to other Georgian issuers'
ability to borrow externally. At this stage, the state is unlikely
to compensate Georgian Railway for investments in Tbilisi Bypass.
However, the government has supported the company's peers with
alternative financing recently. S&P expects the government to take
the same approach for Georgian Railway, if needed.

The stable outlook reflects that pressure from the potential
downgrade of Georgia will likely be offset by strengthening
performance at Georgian Railway. S&P expects that, with lower
finance expenses, thanks to the successful refinancing in June
2021, FFO generation will improve from 2022, with forecast FFO to
debt exceeding 8%, and the company will maintain solid metrics in
the future. The stable outlook also incorporates S&P's view of an
unchanged very high likelihood of Georgian Railway receiving
extraordinary state support and its assessment of liquidity as
adequate, with no large debt maturing until 2028 and no problems in
obtaining waivers for potential covenants breaches.

Upside scenario

Ratings upside is somewhat limited by the potential negative
trajectory of the sovereign rating. For an upgrade, S&P would need
to consider:

-- The pressure on the sovereign rating;

-- The strength of Georgian Railway's stand-alone metrics, with
the likelihood of FFO to debt reaching and sustainably exceeding 8%
from 2022. This could be supported by growth in freight turnover,
translating into higher EBITDA or by operating cost efficiencies,
absent large fluctuations of lari.

Downside scenario

S&P could consider a downgrade if it lowers the sovereign rating on
Georgia, absent expected improvements of Georgian Railway's
operating performance and leverage, with FFO to debt forecast to
stay below 8%.

Although less likely, ratings downside could come from a material
deterioration in liquidity, for example, caused by a breach of
maintenance covenants on the loan and adverse developments in the
local bank system limiting access to Georgian Railway's cash
balances.




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

FRESHWORLD HOLDING III: Moody's Affirms 'B2' CFR, Outlook Stable
----------------------------------------------------------------
Moody's Investors Service affirmed the B2 corporate family rating
and the B2-PD probability of default rating of Freshworld Holding
III GmbH (Freshworld), the holding company for TOI TOI & DIXI Group
GmbH, following the company's proposal to raise EUR95 million in
incremental term loan B which together with cash on balance sheet
will be used to distribute EUR140 million to shareholders.
Concurrently, Moody's has affirmed B2 instrument ratings of the
guaranteed senior secured term loan B maturing in 2026, which is
proposed to be amended and upsized, and the guaranteed senior
secured revolving credit facility (RCF) maturing in 2026, both
issued by Freshworld Holding IV GmbH. The outlook of both entities
is stable.

RATINGS RATIONALE

The affirmation of the ratings with a stable outlook reflects the
strong operating performance of Freshworld over the last quarters
combined with the expectation that current profitability levels
will be sustained in the next 12-18 months. Pro forma the proposed
dividend recap, Freshworld's total adjusted leverage, as measured
by Moody's-adjusted debt/EBITDA, increases by around 0.6x to 4.9x
as of September 2021. Moody's expects Freshworld could deleverage
towards 4.0x over the next 12-18 months based on expectations that
the company's earnings will continue to steadily increase,
supported by favourable industry fundamentals and optimisation
measures implemented by the company, including its pricing
initiatives. EBITA/interest is forecast to remain comfortable at
around 3.5x and free cash flow (FCF) generation is forecast to
remain positive, with FCF/Debt at around 7%. Based on these
forecasts, Moody's considers Freshworld's rating to be strongly
positioned.

The company has shown strong year-to-date performance supported by
the resilient underlying dynamics in the construction sector in
Germany and in Eastern Europe, also boosted by tailwinds from COVID
because of an increased demand for sanitary services, with sales
increasing by 20% for year-to-date September 2021 period compared
to the same period last year. In addition, the successful
implementation of the transformation programme (including its
pricing initiatives) allowed the company to significantly increase
its Moody's- adjusted EBITDA margin to around 32% in the last
twelve months ended September 2021 period, compared to 27% in
2020.

Freshworld's B2 CFR is further supported by (1) its strong market
positions in the sanitary route-based services market with strong
brands and a competitive advantage in terms of cost structure; (2)
favourable underlying growth trends, supported by strict regulatory
requirements and increased hygiene standards amid the coronavirus
pandemic; and (3) a track record of profitability improvements
since LBO by Apax Partners in 2019, supported by the successful
implementation of its transformation programme.

Freshworld's rating is constrained by: (1) its relatively small
size of operations, with limited regional diversification; (2) its
exposure to the cyclical construction market; and (3) event risk
related to debt-financed dividend distributions and/or acquisitions
due to its private equity ownership.

ENVIRONMENTAL, SOCIAL AND GOVERNANCE CONSIDERATIONS

Moody's takes into account the impact of environmental, social and
governance (ESG) factors when assessing companies' credit quality.

Moody's governance assessment for Freshworld incorporates its
highly leveraged capital structure, reflecting high risk tolerance
of its private equity owner. The private equity business model
typically involves an aggressive financial policy and a highly
leveraged capital structure to extract value. The proposed EUR140
million dividend recap follows the EUR115 million shareholder
distribution in 2020.

LIQUIDITY PROFILE

Moody's considers Freshworld's liquidity to be good. The
transaction is expected to leave around EUR50 million of cash on
balance sheet as of September-end 2021 and Freshworld also has
access to the fully undrawn EUR105 million guaranteed senior
secured revolving credit facility (RCF) due 2026. The RCF is
subject to a springing first lien net leverage ratio covenant,
tested when the facility is drawn by more than 40%. The covenant is
set with substantial headroom and Moody's expects Freshworld to
ensure consistent compliance with this covenant at all times.

STRUCTURAL CONSIDERATIONS

The capital structure includes the guaranteed senior secured term
loan and the RCF, which rank pari passu. Accordingly, the B2
instrument rating is aligned with the CFR. The facilities are
guaranteed by the company's subsidiaries and benefit from a
guarantor coverage test of not less than 80% of the group's
consolidated EBITDA. The security collateral includes shares, bank
accounts and intercompany receivables of material subsidiaries.

RATING OUTLOOK

The stable outlook reflects Moody's expectation that the operating
environment will remain robust and that Freshworld will continue to
successfully execute its transformation programme, translating to
mid to high single digit topline growth and Moody's-adjusted EBITDA
margin sustained above 30%. Forecast earnings growth could create
potential for Freshworld to reduce its leverage towards 4.0x
debt/EBITDA over the next 12-18 months. The stable outlook assumes
that Freshworld's FCF will be sustainably positive, with FCF/Debt
in high-single digits in percentage terms, and its liquidity
profile remains good. Based on these forecasts, Moody's considers
Freshworld's rating to be strongly positioned.

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

Upward rating pressure could arise based on expectations for (1)
Moody's-adjusted debt/EBITDA below 4.5x for a sustained period of
time; (2) Moody's-adjusted EBITDA margin of around 30% on a
sustained basis; (3) FCF/debt in the mid to high single digits in
percentage terms on a sustained basis; and (4) good liquidity. A
higher rating would also require the company to commit to
maintaining this less aggressive capital structure.

Conversely, negative rating pressure could arise if (1)
Moody's-adjusted debt/EBITDA increases sustainably above 6.0x; (2)
FCF turns negative on a sustained basis resulting in deterioration
of company's liquidity profile.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Business and
Consumer Services published in November 2021.

COMPANY PROFILE

TOI TOI & DIXI Group GmbH is based in Ratingen, Germany, operates
the well-known DIXI and Toi Toi brands, providing portable toilet
and sanitation equipment rental and services worldwide. The company
is a market leader in eight of its top 10 focus countries. It
achieved a group net sales and adjusted EBITDA of around EUR476
million and EUR154 million, respectively, in the 12 months that
ended September 2021. The company is owned by the funds advised by
Apax Partners and management.

FRESHWORLD HOLDING: Fitch Raises LT IDR to 'B+', Outlook Stable
---------------------------------------------------------------
Fitch Ratings has upgraded Freshworld Holding III GmbH's
(Freshworld, the owner of TOI TOI & DIXI Group GmbH) Long-Term
Issuer Default Rating (IDR) to 'B+' from 'B' with a Stable Outlook.
Fitch has also upgraded the instrument rating of the first-lien
senior secured Term Loan B, issued by Freshworld Holding IV GmbH,
to 'BB-' from 'B+'. Under Fitch's recovery assumptions the recovery
percentage improves to 67% from 54%, still within the 'RR3' band.

The upgrades reflect the group's successful implementation of its
transformation programme which significantly improved profitability
and cash flow generation. The ratings are underpinned on
Freshworld's strong market position in mobile sanitary services
(cabins and containers), the resilience of its earnings and cash
flows as highlighted at the height of the coronavirus pandemic, and
existing organic and inorganic growth potential. Exposure to the
potentially cyclical construction end-market is mitigated by a
fairly stable outlook on the group's most important geographies.

Despite the EUR95 million add-on to the Term Loan B in December
2021, Fitch forecasts leverage will remain below the 6.0x downgrade
threshold on a funds from operations (FFO) leverage basis. Fitch
expects that any further add-ons to the existing indebtedness will,
in conjunction with growth, will keep leverage at levels
commensurate with a 'B+' rating.

KEY RATING DRIVERS

Successful Transformation Programme: The implementation of the
transformation programme started at the beginning of 2020 and has
resulted in a tangible step up in terms of the group's revenue and
EBITDA. This is most visible in Germany, the group's home and most
important market (about 62% of 2020 revenue), and where the
programme was first implemented. Changes in the pricing strategy,
higher take-up of extra services (e.g. higher demand for cabins
equipped with water sink, shorter service intervals) and other
operating measures significantly increased revenue (e.g. 9M21 grew
20% year on year; about 38% above 2019 values) and EBITDA.

The rollout of the transformation programme to other key
geographies for the group, such as Benelux, Poland and Switzerland,
started in 2H21 adds organic growth potential, but the programme's
effectiveness may be lessened by Freshworld's weaker position in
those markets.

Additional Growth Possible: Fitch believes the group has additional
growth avenues. The events business is significantly below
pre-pandemic levels. Having represented an estimated 11% of 2019
revenue, Fitch estimates that 2021 revenue from events will be
between 40% and 50% of 2019 levels. While some uncertainties
related with the pandemic remain, Fitch expects 2022 events revenue
to continue to recover slowly towards 2019 levels. Inorganic growth
through bolt-on acquisitions, building on the group's scale and
consolidating potential, is another opportunity as illustrated by
the acquisition of Benelux-focused Eco Toilet in 2021.

Finally, the expansion of the transformation programme to such
areas as administrative, procurement and fleet costs offers upside
potential to profitability levels. While these initiatives have
been deprioritised in the first stage of the programme they
continue to be available and Fitch expects will be pursued in the
next 24 months.

Financial Policy Record: Freshworld's financial policy exhibits
some discretionary elements driven by decisions from the group's
majority shareholder Apax Partners, an independent private equity
firm. This is illustrated by the two add-ons to the term loan made
in the past 12 months for shareholder distributions, which added
EUR185 million to the group's indebtedness.

Although the risk of further shareholder-friendly actions and the
lack of a stated financial policy reduces Fitch's visibility in
terms of future leverage, Fitch assesses the add-ons as having
established a record that indicates some restraint in re-leveraging
the company. As such, Fitch expects any further increase in
indebtedness will be mitigated by improved in EBITDA and cash flow
generation, and that leverage should remain within Fitch's 'B+'
rating thresholds.

Resilient Construction End-Markets: The medium-term prospects for
the construction end-market are central to Fitch's rating case.
Recent estimates from Fitch Solutions Country & Industry Research
indicate that Europe's construction industry will grow by 4.9% in
2021 in after declining by 5.2% in 2020. The forecast for 2022-2024
points to continued, albeit slower, growth. Freshworld's key
geographies exhibit different growth profiles but Fitch expects
most markets to grow in the next three years owing to a robust and
balanced construction market, reflecting persistent undersupply and
upgrades required for older building stock. Fitch expects that the
deployment of EU's EUR750 billion Next Generation EU fund should
sustain opportunities in green infrastructure projects across the
bloc.

Longstanding Brand and Value Proposition: Freshworld's TOI TOI and
DIXI brands have decades of recognition and solidify the company's
leadership position in Germany, as well as in most other European
markets. Freshworld's strength across the value chain also makes it
the clear top choice for customers, as the waste management aspect
is necessary, although not highly contested. Aside from premium
toilet cabins, Freshworld also offers customisable sanitary
containers and ancillary equipment for larger or longer-term
projects, which regional companies that compete mainly for smaller
projects cannot provide.

Defensive Route-Based Model: Freshworld's business model is
concentrated highly on network density, scale and logistics, and
protects its entrenched position. In Germany, its national market
share is 15x higher than its closest competitor. With more stops
per servicing route, Freshworld can drive down the cost per stop,
leading to a margin advantage. In effect, this creates a barrier to
entry, as it becomes difficult for a competitor without a
comparable presence to operate alongside Freshworld in a given
area.

DERIVATION SUMMARY

Freshworld has no direct Fitch-rated peers. However, other service
businesses in Fitch's ratings universe with strong competitive
positions and high recurring revenue visibility include GfK SE
(BB-/Stable), Irel Bidco S.a.r.l. (IFCO, B+/Stable), TeamSystem
Holding S.p.A. (B/Stable) and Techem Verwaltungsgesellschaft 674
mbH (B/Negative).

GfK's leading position in its chosen segments, clearer financial
policy, lower leverage and margin upside from ongoing restructuring
allows for a higher rating. IFCO is larger and more diversified
than Freshworld, hence allowing it a looser leverage upgrade
sensitivity at 5.0x. Compared with TeamSystem's, Freshworld has
lower leverage Fitch well as a slightly stronger competitive
position and geographical diversification. Techem has a resilient
utility-like business profile allowing for a looser 'B' rating
leverage threshold comparing with Freshworld, but the rating is
constrained by high leverage.

KEY ASSUMPTIONS

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

-- Revenue growth of about 18% in 2021, reflecting overall good
    performance in 9M21 and the acquisition in the Netherlands;
    revenue growth in the mid-to-low single digits in 2022 and
    2023;

-- Fitch-defined EBITDA margin of 30.6% in 2021, gradually
    improving thereafter due to the rollout and expansion of the
    transformation plan;

-- Capex at 9% in 2021 and about 10% from 2022;

-- Extraordinary shareholder distribution of EUR140 million in
    4Q21 financed by EUR95 million term loan add-on and EUR45 cash
    on balance. No other dividend payment assumed;

-- Slightly negative working capital reflecting the business
    growth.

KEY RECOVERY RATING ASSUMPTIONS

The recovery analysis assumes that Freshworld would be considered a
going concern in bankruptcy and that the company would be
reorganised rather than liquidated.

Fitch has assumed a 10% administrative claim.

Post-restructuring going-concern EBITDA of EUR95 million,
reflecting a hypothetical downturn of the construction industry,
which would in turn hinder the implementation and retention of
gains of the transformation programme. The events business would
continue below historical levels for longer than anticipated.

An enterprise value multiple of 6.0x is used to calculate a
post-reorganisation valuation, reflecting Freshworld's dominant and
entrenched position in most large European markets, arising from
its scale and density.

Fitch calculates the recovery prospects for the senior secured
instruments of a EUR660 million TLB at 67%, and assumes a fully
drawn revolving credit facility of EUR105 million. This implies a
one-notch uplift for the instrument rating relative to the
company's IDR to 'BB-' with a Recovery Rating of 'RR3'.

RATING SENSITIVITIES

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

-- FFO gross leverage sustained below 4.5x, combined with a clear
    financial policy and leverage targets;

-- FFO interest coverage above 4.0x;

-- Successful continued rollout of the transformation programme
    and bolt-on acquisitions leading to increased scale with a
    sustained competitive position across Europe.

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

-- FFO gross leverage sustained over 6.0x;

-- FFO interest coverage below 3.0x or a weakening liquidity
    profile;

-- Significant slowdown or downturn in construction end-markets
    or failure to sustain current EBITDA margin levels due to
    weakening of pricing or rise in costs.

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

Satisfactory Liquidity: At end-September 2021 Freshworld had about
EUR95 million in cash and equivalents. Of this, EUR45 million will
be used to finance a EUR140 million extraordinary shareholder
distribution. Fitch expects the business to continue generating
positive FCF. The group's liquidity is further enhanced by an
undrawn revolving credit facility of EUR105 million, maturing in
April 2026.There is no significant debt maturity until the term
loan matures in October 2026.

ISSUER PROFILE

Freshworld, the owner of TOI TOI & DIXI Group, offers
sanitary/toilet cabins, containers and ancillary products and
services to the construction and events industries.

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.

MEDIAN BV: Fitch Assigns Final 'B' LT IDR, Outlook Stable
---------------------------------------------------------
Fitch Ratings has assigned Median B.V. a final Long-Term Issuer
Default Rating (IDR) of 'B' with Stable Outlook. Fitch has also
assigned Median's six-year term loan B (TLB) a final senior secured
debt rating of 'B+' with a Recovery Rating of 'RR3'. The assignment
of final ratings follows the acquisition of the UK-based Priory
Group being completed in line with Fitch's expectations.

The 'B' IDR reflects modest operating cash flow and free cash flow
(FCF) margins, with a limited ability to materially improve
profitability, despite a meaningful increase in scale, due to high
personnel and rental expenses combined with reimbursement pressure.
Rating strengths are the company's leading market positions in the
non-cyclical fragmented medical and mental care rehabilitation
healthcare markets in Germany and the UK, aided by an overall
balanced regulatory environment in both countries.

The Stable Outlook reflects Fitch's view of management's ability to
integrate the transformational acquisition of the Priory Group,
manage costs and continue to grow through bolt-on acquisitions.
This should translate into resilient operating profitability and
stable credit metrics, with funds from operations (FFO)
lease-adjusted leverage remaining at or below 7.0x, which is high
for the credit, but in line with ratings for the sector.

KEY RATING DRIVERS

Pan-European Operator, Diversified Service Offering: The merger of
German rehabilitation specialist Median with UK-based behavioral
healthcare service provider Priory has created a pan-European
healthcare platform to address growing demand for rehabilitation
and mental care in Europe, which has been exacerbated by the
pandemic. Unlike most Fitch-rated EMEA healthcare-service
providers, Median will benefit from geographic diversification
across Europe's larger economies with a high share of healthcare
spending. Leading national market positions, albeit in narrowly
defined areas, with a reasonably diverse range of services, also
contribute to greater operating resilience at the combined entity.

High Execution Risks: Fitch sees high execution risks in the
integration of Priory. It will entail a cultural change at Priory
as Median devolves more responsibilities to individual hospital
managers, in line with the decentralisation of duties from NHS to
local commissioners. This means careful selection of appropriate
personnel at each facility to maximise local competencies while
steering the group centrally. In contrast, Fitch views the
conservatively planned and low-scale synergies, which will be
achieved by centralising or streamlining certain corporate
functions, as low-risk and achievable.

Constructive Regulatory Frameworks: Median benefits from stable and
well-funded state-backed healthcare systems in Germany and the UK,
with constructive pricing policies allowing private operators to
pass on most inflationary cost increases. The German state promotes
rehabilitation care over disability pension to reduce the
longer-term burden on the social care system by reintegrating
patients into work and social life after an acute medical
treatment. In the UK, the government's funding pledge for adult
mental health to receive a growing share of the NHS's budget of at
least GP2.3 billion a year by 2023/2024 provides a supportive
framework for independent operators such as Median.

High Operating Leverage: The 'B' IDR reflects Median's high
operating leverage, due to a large proportion of fixed costs,
particularly with regard to personnel and rental costs, which Fitch
estimates at around 60% and 10% of revenue, respectively. This
means any larger-than-expected adverse change in occupancy,
reimbursement or personnel costs may materially affect core
profitability. Median's cost base is subject to long-term
underlying trends in the healthcare services sector such as a lack
of qualified staff, which could intensify in the UK due to Brexit,
and tighter supervision and care standards.

Deleveraging Limited: Fitch projects FFO lease-adjusted gross
leverage at or slightly below 7.0x until 2024, which is less
aggressive than that of European sector peers such as Mehilainen
Yhtyma Oy. Fitch sees limited organic deleveraging scope, given
modest operating and cash flow margins, and potential investments
in bolt-on acquisitions.

Strengthening Medium-Term FCF: The ability of Median to achieve
positive FCF on a sustained basis, together with leverage, is a
decisive factor in differentiating 'B' from 'B-' rated sector
credits. Fitch projects the FCF margin for the combined group to be
in positive low single digits, assuming a stable EBITDA margin at
around 10%, versus neutral-to-negative for Median prior to the
merger.

Projected Stable EBITDA Margin: Fitch views the profitability of
10% as achievable, subject to the business regaining pre-pandemic
occupancy rates from 2022. EBITDA margin could benefit from further
increases in occupancy rates, an improved patient mix and higher
acuity level in the UK as well as reimbursement- rate increases in
Germany that are marginally offset by lower-rate service and payor
mix.

Tight Coverage Metrics: Following the merger, Fitch projects that
Median's FFO fixed charge cover will remain at 1.5x, which is low
for the rating. Rental costs account for around 10% of revenue in
Fitch's forecasts, making up for a considerable part of debt-like
service costs. A reduction of the FFO fixed charge cover to below
1.5x, combined with increased leverage, would signal a weakening
financial risk profile and could put ratings under pressure.

Latent M&A Risk: Median's intention to make further significant
acquisitions in Germany and internationally is an event risk,
albeit presumably from 2022, once the integration of Priory has
sufficiently advanced. Fitch factors in bolt-on acquisitions of up
to EUR100 million a year funded with a mix of internal cash flows
and incremental debt. Median's record of lowering acquisition
multiples by sale & leaseback transactions of the property of
acquisition targets yields deleveraging potential. Fitch views the
rating impact of larger acquisitions as event risk, subject to
their business risk and integration complexity, as well as
acquisition economics and funding mix.

DERIVATION SUMMARY

Fitch rates Median under Fitch's the framework of the ratings
navigator for healthcare providers. Global sector peers tend to
cluster in the 'B'/'BB' range, driven by the traits of their
respective regulatory frameworks influencing the quality of funding
and government healthcare policies, as well companies' operating
profiles, including scale, service and geographic diversification,
and payor and medical indication mix. Many sector providers pursue
debt-funded M&A strategies, given the importance of scale and
limited room for maximising organic return.

The 'B' IDR of Median reflects its pan-European operations in
generally balanced regulatory frameworks, albeit with limited scope
for profitability improvement given sector-specific high operating
leverage. Its credit risk profile is in line with Mehilainen Yhtyma
Oy's (B/Stable), with lower operating and cash flow margins being
offset by its larger scale and broader geographic diversification.
Fitch tolerates higher FFO adjusted leverage of 8.0x for Mehilainen
versus 7.5x for Median, given the former's record of
mid-single-digit FCF margin compared with Median's negative FCF
margin (prior to the merger). The latter is projected to turn
positive from 2022, subject to meaningful execution risks.

Median is rated at the same level as the French hospital operator
Almaviva Developpement SAS (B/Stable) and a number of privately
rated EMEA-based hospital groups, all of which have similar
operating characteristics of stable patient demand with a regulated
but limited ability to enforce price increases above inflation, and
the necessity of driving operating efficiencies while maintaining
well-invested clinic networks to safeguard competitive
sustainability.

The ratings of EMEA sector peers tend to be constrained by weak
credit metrics, expressed in highly leveraged balance sheets as a
result of continuing national and cross-border market consolidation
with FFO adjusted leverage at 7.0x-8.0x and tight FFO fixed-charge
cover of 1.5x-2.0x.

KEY ASSUMPTIONS

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

-- Organic revenue growth at low single digits in 2021, mid-
    single digits in 2022 and low single digits in 2023 and 2024;

-- Annual acquisitions of EUR100 million over 2022-2024, boosting
    revenue growth to high-single digits;

-- EBITDAR margin fluctuating around 20.5% over 2021-2024;

-- Rent expense slightly below 11% of sales over 2021-2024,
    leading to EBITDA margin slightly below 10% over 2021-2024;

-- Capex gradually easing to 4% of revenue in 2024 from 4.4% in
    2021;

-- No dividends.

Key Recovery Assumptions:

In the recovery analysis Fitch assumes that Median would be
reorganised as a going-concern (GC) in bankruptcy rather than
liquidated, given its strong market position across selected
services lines in Germany and the UK and a high share of rented
estate.

Fitch has assumed a 10% administrative claim.

Fitch estimates Median's GC EBITDA at around EUR120 million,
reflecting potential integration challenges, adverse regulatory
changes leading to declining occupancy rates, unfavourable shift in
payor/medical indication mix, or rising costs, especially as the
personnel-intensive business is plagued by staff shortages.

An enterprise value/EBITDA multiple of 6.0x is applied to the GC
EBITDA to calculate a post-reorganisation enterprise value. This
multiple considers the social-infrastructure asset nature of the
healthcare business, supported by long-term demand and high
barriers to entry; geographic diversification and constructive
regulatory frameworks; and trading and acquisition multiples of
listed sector peers averaging at 10.0x-12.0x.

The multiple is 0.5x below that of Mehilainen, whose business
benefits from wide diversification across healthcare and social
care, a leading market position in Finland - now also growing
abroad - with higher cost variability and lower capital intensity,
given its exposure to occupational health and outpatient care. At
the same time, Median's GC multiple is in line with that of other
national hospital operators, such as Almaviva Developpement, as
well as several privately rated EMEA sector peers.

After deducting 10% for administrative claims, Fitch's waterfall
analysis generates a ranked recovery for the senior secured TLB in
the 'RR3' category, leading to a 'B+' senior secured rating, which
includes a pari passu-ranking revolving credit facility of EUR120
million that Fitch assumes will be fully drawn prior to distress.
This results in a waterfall-generated recovery computation output
percentage of 70% based on current metrics and assumptions.

RATING SENSITIVITIES

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

-- Successful merger of Median and Priory and achievement of
    synergies leading to sustained revenue growth and EBITDA
    margins improving towards 12%;

-- Improvement in FCF margin to mid-single digits;

-- FFO adjusted gross leverage below 6.0x on a sustained basis;

-- FFO fixed charge cover above 2.0x on a sustained basis.

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

-- Risk to the business model resulting from adverse regulatory
    changes to public and private funding in Germany and the UK,
    or challenges in executing the Median-Priory merger leading to
    erosion of EBITDA margin to below 9%;

-- Inability to improve FCF margins to mildly positive levels;

-- FFO adjusted gross leverage above 7.5x on a sustained basis;

-- FFO fixed charge cover below 1.5x on a sustained basis.

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

Satisfactory Liquidity: Fitch expects Median to have satisfactory
liquidity, due to full availability under its EUR120 million
undrawn revolving credit facility maturing in May 2027 in addition
to modest cash on balance of around EUR25 million (excluding
Fitch-defined minimum operating cash of EUR25 million deemed
unavailable for debt service). Moreover, Median's liquidity will
benefit from a lack of debt repayments until November 2027.

ESG CONSIDERATIONS

Median has an ESG Relevance Score of '4' for Exposure to Social
Impact, due to operations in a healthcare market that is subject to
sector regulation, as well as budgetary and pricing policies
adopted in Germany and the UK. Rising healthcare costs expose
private-hospital operators to high risks of adverse regulatory
changes, which could constrain companies' ability to maintain
operating profitability and cash flows. This has a negative impact
on the credit profile and is relevant to the rating in conjunction
with other factors.

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

ISSUER PROFILE

Median is the result of the private equity sponsor-led merger of
Median (Germany) and Priory (UK), providers of medical
rehabilitation and mental care services.

STANDARD PROFIL: Moody's Affirms B3 CFR, Alters Outlook to Neg.
---------------------------------------------------------------
Moody's Investors Service has affirmed the B3 corporate family
rating, B3-PD probability of default rating as well as a B3 backed
senior secured instrument rating for automotive parts supplier
Standard Profil Automotive GmbH and changed the outlook on the
ratings to negative from stable.

RATINGS RATIONALE

The change in outlook to negative was driven by a much weaker
operating performance of the company in the first nine months of
2021, in particular in Q3 2021, which will result in Standard
Profil not reducing its high gross leverage as it was expected by
Moody's previously. A significant amount of cash burn in the first
nine months and no alternative liquidity arrangements might raise
concerns about the company's liquidity profile absent any recovery
of profits and cash flows over the next quarters or anticipated
signing of a revolving credit facility. In addition to the
semiconductor shortage and increased raw material prices, the
operational losses at Standard Profil's plant in Mexico had a
materially negative impact on the 9months and Q3 operating
performance.

Consequently, in contrast to Moody's previous expectations that the
company will be able to reduce gross leverage (Moody's adjusted
gross debt to EBITDA) to around 6.5x in 2021 from a pro forma
leverage of 11.4x in 2020, Moody's now anticipate a gross leverage
to be around 12x, even somewhat above the level in 2020. This will
be mainly driven by a significantly lower adjusted EBITDA
generation compared to Moody's initial expectation together with a
sizable consumption of working capital leading to a deterioration
of the company's liquidity profile.

The CFR of Standard Profil remains primarily constrained by the
company's (1) exposure to the cyclicality of the global automotive
industry; (2) a competitive market environment for sealing
solutions with a sizeable number of competitors that does not allow
for meaningful product differentiation, (3) the high exposure to
raw materials like synthetic rubber and carbon black, which the
supplier is challenged to fully pass through to the OEM and could
result in material volatility in profits, (4) its limited scale and
low profitability, and (5) its high leverage of around 12x in
2020.

The rating is supported by the company's (1) strong position in the
market for automotive sealing solutions in Europe as evidenced by
recent high profile product wins and a solid order book at this
point, (2) its global production footprint in best cost countries
that enables a cost advantage in the labor intensive business, (3)
its vertically integrated business, where the in house production
of tooling leads to lower lead times for new business contracts,
(4) the ongoing trend towards bulkier cars (SUVs) and Electric
Vehicles that is expected to benefit Standard Profil's content per
vehicle and should provide an outperformance compared to Moody's
light vehicle sales expectations.

LIQUIDITY

Moody's consider Standard Profil's liquidity to be weak. As of the
end of September 2021, the company's cash balance was EUR47.5
million. The group does not have access to a revolving credit
facility but has the intention to sign one in due course. On a
regional level, banks provide bilateral facilities of around EUR15
million, which are not included in Moody's liquidity assessment due
to their short term nature. There are no major short-term
maturities until 2026 when the issued notes are due.

RATING OUTLOOK

The negative outlook reflects the risk that Standard Profil will
not be able to de-lever and achieve a Moody's adjusted leverage
below 6.0x in the next 12-18 months as assumed for the B3 rating.
The inability to provide additional liquidity sources such as by
securing the targeted credit facility would put further pressure on
the rating.

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

The ratings could be downgraded in case of (i) Standard Profil's
leverage in terms of Moody's adjusted debt/EBITDA remaining above
6.5x for a prolonged period, or (ii) continued negative Free Cash
Flow leading to a reduction in the liquidity position, in the
absence of a committed credit facility.

Standard Profil's rating is currently very weakly positioned and
therefore an upgrade over the next 12-18 months is rather unlikely.
However, an upgrade could be envisaged should (i) Moody's adjusted
debt/EBITDA fall below 5.0x on a sustained basis, and (ii) Moody's
adjusted EBITA margin above 4.0% on a sustained basis, and (iii)
Moody's adjusted EBITA/Interest expense above 1.0x on a sustained
basis, as well as (iv) a sustained positive Free Cash Flow
generation.

STRUCTURAL CONSIDERATIONS

Standard Profil's PDR of B3-PD is in line with its B3 CFR, which
reflects Moody's typical 50% corporate family rating recovery
assumption for all-senior capital structures. The B3 ratings of the
senior secured facilities are also in line with the CFR, reflecting
the all-senior capital structure. Moody's rank EUR45.4 million
Trade Payables, EUR24.2 million lease liabilities and EUR8 million
pension liabilities in line with the senior secured notes.

ESG CONSIDERATIONS

Standard Profil is owned by private equity group Actera since 2013.
This governance consideration has been included in the ratings
consideration.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Automotive
Suppliers published in May 2021.

COMPANY PROFILE

Headquartered in Eschborn, Germany, Standard Profil Automotive GmbH
is a tier 1 supplier to the automotive industry. The company is
offering static and dynamic sealing solutions to global automotive
manufacturer. In the first nine months 2021 the company generated
revenues of EUR234 million and a company adjusted EBITDA margin of
11.5%. Since 2013 the company is owned by Actera, a private equity
firm with offices in Jersey and Turkey.



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

FROST CMBS 2021-1: DBRS Gives Prov. BB(high) Rating on E Notes
--------------------------------------------------------------
DBRS Ratings Limited assigned provisional ratings to the following
classes of notes to be issued by Frost CMBS 2021-1 DAC (the
Issuer):

-- Class A (GBP) notes at AAA (sf)
-- Class B (GBP) notes at AAA (sf)
-- Class C (GBP) notes at AA (sf)
-- Class D (GBP) notes at A (low) (sf)
-- Class E (GBP) notes at BBB (sf)
-- Class F (GBP) notes at BBB (low) (sf)
-- Class A (EUR) notes at AAA (sf)
-- Class B (EUR) notes at AA (sf)
-- Class C (EUR) notes at A (low) (sf)
-- Class D (EUR) notes at BBB (low) (sf)
-- Class E (EUR) notes at BB (high) (sf)

The trends on all ratings are Stable.

The transaction is a securitization of two commercial real estate
(CRE) loans (the Transaction) advanced by Goldman Sachs Bank Europe
SE (Goldman Sachs) to entities owned and managed by NewCold
European Holding B.V. (NewCold), which is ultimately owned by
Newcold Holdings LLC (the Sponsor), a temperature-controlled
logistics company based in the Netherlands. One loan is denominated
in British pounds sterling (the GBP Loan or Facility A) and is
secured by a single cold-storage property in Wakefield, Yorkshire,
UK (the Wakefield Property). The other is denominated in euros (the
EUR Loan or Facility B) and is secured against one cold-storage
asset in Rheine, Westphalia, Germany (the Rheine Property) and one
in Argentan, France (the Argentan Property). Together, the GBP Loan
of GBP 112.35 million and the EUR Loan of EUR 92.0 million form the
loan under the facilities agreement. The purpose of the loan is to
refinance existing indebtedness or, in respect of the Argentan
Property, refinance the purchase of the Argentan Property, to pay
related financing costs and for the NewCold Group's general
corporate purposes.

NewCold built the Rheine Property and the Wakefield Property in
2013. Subsequently, the Wakefield Property was significantly
expanded in 2017. Both properties comprise temperature-controlled
and ambient storage facilities. The Argentan Property, also a
temperature-controlled storage facility, was built and acquired by
NewCold in 2012. The portfolio of three cold-storage properties is
largely automated with high bay access and offers a total pallet
capacity size of 304,928 pallets across 62,844,671 cubic feet.

As of June 30, 2021, the portfolio was approximately 85.4% occupied
and 65.8% of the capacity was occupied by customers with Operating
Service Agreements (OSA) as at December 2020. NewCold benefits from
longstanding customer relationships and global OSAs, including
those with, among others, Froneri International (Froneri) and
McCain Foods Limited (McCain), which, on a weighted-average (WA)
basis, equates to a contract term of 7.9 years. The assets are
located strategically close to customers' distribution centers as
well as their target markets, placing NewCold as an integral part
of the supply chain process for most of its key customers. The top
10 total customers contributed 80.3% to 2020 portfolio revenue with
the top seven contributing 75.1% of total revenue. Froneri made up
35.4% of total 2020 revenue and is present in Wakefield, Rheine,
and Argentan (to a lesser extent). McCain made up 17.1% of total
2020 revenue.

While the facilities agreement provides that the income (including
interest) and principal received in respect of the Wakefield
Property is allocated to prepay or repay the GBP Loan and the
income (including interest) and principal received in respect of
the Rheine Property and the Argentan Property is allocated to
prepay or repay the EUR Loan, the GBP Loan and the EUR Loan are
cross-collateralized, include cross-default provisions, and secured
by all three properties. Cash flows arising in respect of the
Wakefield Property will be used first to make payments under the
GBP notes and cash flows in respect of the Rheine Property and the
Argentan Property will be used first to make payments under the EUR
notes; however, due to the cross-collateralization and
cross-default features in the facilities agreement, the GBP
noteholders will be exposed to the performance of the EUR Loan and
the two European properties while the EUR noteholders will be
exposed to the performance of the GBP Loan and the Wakefield
Property, including in each case any related foreign-exchange risk
relating to the then-applicable GBP/EUR exchange rate.

The GBP Loan and the EUR Loan represent moderate-leverage financing
with a loan-to-value (LTV) ratio of 60.5% and 62.4%, respectively,
based on CBRE Limited's (CBRE) 1 October 2021 valuation of GBP
185.6 million for the Wakefield Property, EUR 108.4 million for the
Rheine Property, and EUR 39.1 million for the Argentan Property.
DBRS Morningstar derived its calculated LTV of 78.4% and 79.1% for
the GBP and EUR Loans, respectively, from DBRS Morningstar's
valuations of GBP 143.3 million and EUR 114.3 million,
respectively. This relatively higher LTV is mitigated by cash trap
covenants set at an LTV of 68.77% and a debt yield (DY) of 8.74%
for the initial loan term. DBRS Morningstar notes that the cash
trap covenants contained in the facilities agreement are calculated
on an aggregate basis and any appraisal reductions are determined
at a portfolio level. In these circumstances, while a base currency
concept is applied, there is a related foreign-exchange exposure
relating to the then-applicable GBP/EUR exchange rate.
Additionally, the facilities agreement sets out financial default
covenants, which are also calculated on an aggregated basis. The
financial default covenants are such that the LTV must at all times
be less than or equal to 76.27% and the DY on each loan interest
payment date is greater than 7.71%. Based on a reported trailing
12-month (T-12) net operating income (NOI) to June 2021 of GBP
11.68 million and EUR 10.30 million, the DY at the utilization date
of 18 October 2021 was 10.4% for the GBP-denominated notes and
11.2% for the EUR-denominated notes. Accordingly, DBRS
Morningstar's computed day-one DY is 9.5% for the GBP Loan and 9.3%
for the EUR Loan, and is determined from a DBRS Morningstar net
cash flow (NCF) assumption of GBP 10.69 million and EUR 8.54
million on the GBP Loan and the EUR Loan, respectively. The loans
will bear interest equal to the sterling overnight index average
(Sonia) plus the loan margin of 3.25% in respect of the GBP Loan
and three-month Euribor plus the loan margin of 2.8%, in respect of
the EUR Loan for the term of the loan. The interest rate risk is to
be fully hedged in accordance with the terms of the facilities
agreement, including by a prepaid cap with a strike rate of 2.0%
provided by a hedge provider with a rating and relevant triggers,
as at the cut-off date, commensurate with that of DBRS
Morningstar's rating criteria.

Each borrower must repay the loans made available to it on the
fifth, sixth, seventh, and eighth loan interest payment dates in an
amount equal to 0.25%. Thereafter, if certain conditions pertaining
to DY, LTV, and capital expenditures (capex) in respect of the
Rheine Property are not satisfied, the loan will further amortize
by 0.25% per quarter if the DY at the time is higher than 10.31% or
by 0.50% per quarter otherwise.

The initial loan maturity date is in November 2024; however, two
one-year extension options are available provided that (1) no cash
trap event or loan default is continuing or would occur as a result
of the extension and (2) hedging agreements in respect of the
relevant extended period have been entered into that comply with
the terms of the facility agreement. Based on the premise that the
loans will be fully extended, the Transaction is expected to repay
in full by November 2026. If the loans are not repaid by then, the
Transaction will have seven years to allow the special servicer to
work out the loan(s) by November 2033 at the latest, which is the
legal final maturity date.

Any excess Issuer cash flows in either currency will be applied to
satisfy the Issuer's obligations under the relevant Class X notes,
made up of the Class GBP-X notes and the Class EUR-X notes. The
transaction as a whole features a Class X interest diversion
structure where the Class X diversion trigger is aligned with the
financial covenants of the loans; once triggered, any interest and
prepayment fees due to the respective Class X noteholders will
instead be paid directly into the Issuer's transaction account and
credited to the Class GBP-X or Class EUR-X diversion ledger. The
diverted amount will be released once the trigger is cured; only
following the expected note maturity or the delivery of a note
acceleration notice can such diverted funds be used to amortize the
notes and the Issuer loan, which is described in the next
paragraph.

To maintain compliance with applicable regulatory requirements,
Goldman Sachs Bank USA will retain an ongoing material economic
interest of no less than 5% of the securitization via an Issuer
loan, which Goldman Sachs Bank USA will advance on the closing
date. The Issuer will also establish two reserves: (1) in respect
of the GBP notes, the Issuer GBP liquidity reserve and (2) in
respect of the EUR notes, the Issuer EUR liquidity reserve, which
will be credited with the relevant initial Issuer liquidity reserve
required amount. Part of the noteholders' subscription for the
Class A (GBP) notes and Class A (EUR) notes will be used to provide
95% of the liquidity support for the Transaction, which is
initially set at GBP 2,861,579 and EUR 4,206,316 or 2.5% of the
total outstanding balance of the GBP notes and 4.6% of the total
outstanding balance of the EUR notes, respectively. The remaining
5% will be funded by the Issuer loan. DBRS Morningstar understands
that the liquidity reserve in respect of the GBP Notes will cover
the interest payments to Class A to Class D of the GBP notes and
the liquidity reserve in respect of EUR Notes will cover the
interest payments to Class A to Class D of the EUR notes. No
liquidity withdrawal can be made to cover shortfalls in funds
available to the Issuer to pay any amounts in respect of interest
due on the Class E (GBP) notes or the Class F (GBP) notes or the
Class E (EUR) notes. The Class E (GBP), Class E (EUR), and the
Class F (GBP) notes are subject to an available funds cap where the
shortfall is attributable to an increase in the WA margin of the
notes.

Based on a cap strike rate of 2%, DBRS Morningstar estimates that
the liquidity reserve will cover 12 months of interest payments in
respect of the covered GBP notes and 18 months of interest payments
in respect of the covered EUR notes. It is anticipated that
interest rates on the notes will be capped at 4% plus their
respective margins. Based on a Sonia and a Euribor cap of 4.00%,
DBRS Morningstar estimates that the liquidity reserve will cover
nine months of interest payments in respect of the covered GBP
notes and 14 months of interest payments in respect of the covered
EUR notes, assuming the Issuer does not receive any revenue.

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 arise for many
commercial mortgage-backed security (CMBS) borrowers, some
meaningfully. In addition, commercial real estate values will be
negatively affected, at least in the short term, affecting
refinancing prospects for maturing loans and expected recoveries
for defaulted loans.

Notes: The principal methodology applicable to the ratings is:
"European CMBS Rating and Surveillance Methodology" (February 26,
2021).


INVESCO EURO: Fitch Affirms B- Rating on 4 Note Classes
-------------------------------------------------------
Fitch Ratings has affirmed Invesco Euro CLO I DAC, Invesco Euro CLO
III DAC , Invesco Euro CLO IV DAC and Invesco Euro CLO V DAC and
removed all class notes, except class A and X, from Under Criteria
Observation (UCO). The Outlook is Stable.

    DEBT                 RATING            PRIOR
    ----                 ------            -----
Invesco Euro CLO V DAC

A XS2269329921      LT AAAsf   Affirmed    AAAsf
B-1 XS2269330184    LT AAsf    Affirmed    AAsf
B-2 XS2269330341    LT AAsf    Affirmed    AAsf
C XS2269330697      LT Asf     Affirmed    Asf
D XS2269330853      LT BBB-sf  Affirmed    BBB-sf
E XS2269331075      LT BB-sf   Affirmed    BB-sf
F XS2269331232      LT B-sf    Affirmed    B-sf
X XS2269329848      LT AAAsf   Affirmed    AAAsf

Invesco Euro CLO IV DAC

A XS2114940187      LT AAAsf   Affirmed    AAAsf
B-1 XS2114941078    LT AAsf    Affirmed    AAsf
B-2 XS2114941748    LT AAsf    Affirmed    AAsf
C XS2114942555      LT Asf     Affirmed    Asf
D XS2114943108      LT BBB-sf  Affirmed    BBB-sf
E XS2114943876      LT BB-sf   Affirmed    BB-sf
F XS2114943520      LT B-sf    Affirmed    B-sf
X XS2114940260      LT AAAsf   Affirmed    AAAsf

Invesco Euro CLO III DAC

A XS2072089902      LT AAAsf   Affirmed    AAAsf
B-1 XS2072090587    LT AAsf    Affirmed    AAsf
B-2 XS2072091478    LT AAsf    Affirmed    AAsf
C XS2072092013      LT Asf     Affirmed    Asf
D XS2072092799      LT BBB-sf  Affirmed    BBB-sf
E XS2072093334      LT BB-sf   Affirmed    BB-sf
F XS2072093508      LT B-sf    Affirmed    B-sf

Invesco Euro CLO I DAC

A-1R XS2301385832   LT AAAsf   Affirmed    AAAsf
A-2R XS2301386483   LT AAAsf   Affirmed    AAAsf
B-R XS2301387374    LT AAsf    Affirmed    AAsf
C-R XS2301387960    LT Asf     Affirmed    Asf
D-R XS2301388695    LT BBB-sf  Affirmed    BBB-sf
E XS1911621701      LT BBsf    Affirmed    BBsf
F XS1911622188      LT B-sf    Affirmed    B-sf

TRANSACTION SUMMARY

The transactions are cash flow CLOs mostly comprising senior
secured obligations. They are actively managed by Invesco European
RR L.P. and are within their reinvestment period.

KEY RATING DRIVERS

CLO Criteria Update and Cash Flow Modelling (Neutral): The rating
actions mainly reflect the impact of Fitch's recently updated CLOs
and Corporate CDOs Rating Criteria, a shorter risk horizon
incorporated into Fitch's stressed portfolio analysis, and stable
performance of the transactions.

The weighted average life (WAL) used for each transaction's
stressed portfolio analysis was up to 12 months less than the
current WAL covenant of each transaction. For Invesco I, III and IV
the WAL modelled was floored at six years. This reduction to the
risk horizon takes into account the strict reinvestment conditions
in all the transactions after their reinvestment period. These
include, among others, requirement to pass the coverage tests and
the Fitch 'CCC' concentration limitation tests, as well as a WAL
covenant that steps down over time, both before and after the end
of the reinvestment period. This ultimately reduces the maximum
possible risk horizon of the portfolio when combined with loan
prepayment expectations.

Matrix Update (Neutral): The manager has amended the documentation
of each CLO to reflect Fitch's latest Fitch-weighted average rating
factor (WARF) and average recovery rate (WARR) definitions and the
updated collateral quality matrix. The WARR values in the
collateral quality tests for all four CLOs are in the process of
being lowered to be in line with the break-even WARR, at which the
current ratings would still pass.

Fitch has reflected these updated matrices in its stressed
portfolio analysis that produced the model-implied ratings (MIR).
The current ratings for all notes are in line with these MIRs,
leading to their affirmation. The class F notes in all four
transactions have at least a limited margin of safety against
default risk, as they are passing at least 'Bsf' under the current
portfolio analysis.

Diversified Portfolios (Positive): The portfolios are
well-diversified across obligors, countries and industries. In
Invesco V, the most concentrated portfolio, the largest issuer and
10-largest issuers per Fitch's current portfolio analysis represent
no more than 2.6% and 20.2% of the portfolio, respectively. No
transaction reports an exposure to the largest Fitch-defined
industry and the three-largest Fitch-defined industries above their
respective limit of 17.5% and 40%.

Stable Asset Performance (Neutral): As of the latest trustee
reports available, the transactions were passing all collateral
quality, portfolio profile, and coverage tests. Exposure to assets
with a Fitch-derived rating (FDR) of 'CCC+' and below was reported
by the trustee at 3.8%, 5.8%, 4.6% and 2.8% respectively in Invesco
I, III, I and V, compared with the 7.5% limit. Exposure to
defaulted assets was between 1.1% and 1.7% of the portfolios.

'B'/'B-' Portfolio (Neutral): Fitch assesses the average credit
quality of the obligors at the 'B'/'B-' rating level. The
trustee-calculated Fitch WARF in Invesco I, III, IV and V was
respectively 34.1, 34.6, and 34.2 as of the October 2021 investor
report, marginally under the maximum limit of 34.5 in Invesco V, 35
in Invesco I and IV and 36 in Invesco III. The Fitch-calculated
WARF is between 25.6 and 26.1 in the four transactions after
applying the recently updated CLO Criteria.

High Recovery Expectations (Neutral): At least 90% of the
portfolios comprises senior secured obligations. Fitch views the
recovery prospects for these assets as being more favourable than
for second-lien, unsecured and mezzanine assets. The Fitch WARR of
the current portfolio is reported by the trustee at 64%, 65.9%,
66.0% and 62.5%, compared with the covenant minimum of 59.1%,
65.3%, 64.6% and 64.1%, respectively in Invesco I, III, IV and V.

RATING SENSITIVITIES

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

-- An increase of the rating default rate (RDR) at all rating
    levels by 25% of the mean RDR and a 25% decrease of the
    recovery rate at all rating levels would lead to downgrades of
    up to three notches for the rated notes of Invesco I, up to
    four notches for Invesco III and Invesco IV, and up to five
    notches for Invesco V.

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

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

-- A reduction of the RDR at all rating levels by 25% of the mean
    RDR and a 25% increase of the recovery rate at all rating
    levels, would lead to upgrades of up to five notches for the
    rated notes across the four transactions, except the class A
    and X 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
    in case of a better-than-initially expected portfolio credit
    quality and deal performance, leading to higher credit
    enhancement and excess spread available to cover losses in the
    remaining portfolio.

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

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

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

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

JUBILEE 2021-XXV: Fitch Rates Class F Notes Final 'B-'
------------------------------------------------------
Fitch Ratings has assigned Jubilee CLO 2021-XXV DAC final ratings.

    DEBT                          RATING
    ----                          ------
Jubilee CLO 2021-XXV DAC

A XS2402442920              LT AAAsf   New Rating
B-1 XS2402444033            LT AAsf    New Rating
B-2 XS2402443142            LT AAsf    New Rating
C-1 XS2402444116            LT Asf     New Rating
C-2 XS2402443498            LT Asf     New Rating
D XS2402444546              LT BBB-sf  New Rating
E XS2402444462              LT BB-sf   New Rating
F XS2402444629              LT B-sf    New Rating
Subordinated XS2402443902   LT NRsf    New Rating

TRANSACTION SUMMARY

Jubilee CLO 2021-XXV DAC is a securitisation of mainly senior
secured obligations (at least 92.5%) with a component of senior
unsecured, mezzanine, second-lien loans, first-lien, last-out loans
and high-yield bonds. Note proceeds have been used to fund a
portfolio with a target par of EUR400 million. The portfolio is
actively managed by Alcentra Ltd. The transaction has a 4.5-year
reinvestment period and an 8.75-year weighted average life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors at 'B'/'B-'. The Fitch-weighted
average rating factor (WARF) of the identified portfolio is 24.9.

High Recovery Expectations (Positive): At least 92.5% 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
61.65%.

Diversified Portfolio (Positive): The transaction has a top-10
obligors' concentration limit of 17% and fixed-rate obligations
limit of 12.5%. The transaction also includes various concentration
limits, including a 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 4.5-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed-case portfolio with the aim of testing the robustness of
the transaction structure against its covenants and portfolio
guidelines.

The manager can change the collateral quality tests based on two
Fitch matrices: one effective at closing and one that can be
selected by the manager at any time from one year after closing as
long as the collateral balance (including defaulted obligations at
their Fitch collateral value) is above target par.

Cash Flow Modelling (Neutral): The WAL used for the transaction
stress portfolio is 7.75 years, 12 months less than the WAL
covenant, to account for structural and reinvestment conditions
after the reinvestment period. These include passing the
over-collateralisation and Fitch 'CCC' limitation tests, which,
combined with loan pre-payment expectations, ultimately reduce the
maximum possible risk horizon of the portfolio.

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 defaults and portfolio
    deterioration.

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

-- A 25% reduction of the mean RDR across all ratings and a 25%
    increase in the RRR across all ratings would result in
    upgrades of no more than five 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.

SUMMARY OF FINANCIAL ADJUSTMENTS

Financial statements were not used in the ratings analysis.

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.

JUBILEE CLO 2021-XXV: Moody's Assigns B3 Rating to Class F Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to the Notes issued by Jubilee CLO
2021-XXV DAC (the "Issuer"):

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

EUR23,500,000 Class B-1 Senior Secured Floating Rate Notes due
2035, Definitive Rating Assigned Aa2 (sf)

EUR16,500,000 Class B-2 Senior Secured Fixed Rate Notes due 2035,
Definitive Rating Assigned Aa2 (sf)

EUR18,000,000 Class C-1 Deferrable Mezzanine Floating Rate Notes
due 2035, Definitive Rating Assigned A3 (sf)

EUR10,000,000 Class C-2 Deferrable Mezzanine Fixed Rate Notes due
2035, Definitive Rating Assigned A3 (sf)

EUR25,000,000 Class D Deferrable Mezzanine Floating Rate Notes due
2035, Definitive Rating Assigned Baa3 (sf)

EUR20,000,000 Class E Deferrable Junior Floating Rate Notes due
2035, Definitive Rating Assigned Ba3 (sf)

EUR11,750,000 Class F Deferrable Junior Floating Rate Notes due
2035, 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.

The Issuer is a managed cash flow CLO. At least 92.5% of the
portfolio must consist of senior secured obligations and up to 7.5%
of the portfolio may consist of senior unsecured obligations,
second-lien loans, mezzanine obligations and high yield bonds. The
portfolio is expected to be about 75% 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 six month ramp-up period in compliance with the
portfolio guidelines.

Alcentra Limited ("Alcentra") 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 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. Additionally, the
issuer has the ability to purchase loss mitigation loans using
principal proceeds subject to a set of conditions including
satisfaction of the par coverage tests.

In addition to the eight classes of Notes rated by Moody's, the
Issuer will issue EUR34,500,000 Subordinated Notes due 2035 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 collateral manager'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: EUR400,000,000.00

Diversity Score: 50

Weighted Average Rating Factor (WARF): 3040

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 4.50%

Weighted Average Recovery Rate (WARR): 43.50%

Weighted Average Life (WAL): 8.75 years

MADISON PARK XIV: Fitch Rates Class F-R Notes 'B-(EXP)'
-------------------------------------------------------
Fitch Ratings has assigned Madison Park Euro Funding XIV DAC
refinancing notes expected ratings.

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

DEBT             RATING
----             ------
Madison Park Euro Funding XIV DAC

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

TRANSACTION SUMMARY

Madison Park Euro Funding XIV DAC is a cash flow collateralised
loan obligation (CLO) actively managed by the manager, Credit
Suisse Asset Management. The reinvestment period is scheduled to
end in January 2024. The class A-1, B-1, C-1, D, E and F notes are
being refinanced.

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors at 'B'/'B-'. The
Fitch-calculated weighted average rating factor (WARF) of the
current portfolio is 24.8.

High Recovery Expectations (Positive): The portfolio comprises of
99.6% senior secured obligations. Fitch views the recovery
prospects for these assets as more favourable than for second-lien,
unsecured and mezzanine assets. The Fitch-calculated weighted
average recovery rate (WARR) of the portfolio is 63.5%.

Diversified Portfolio (Positive): The indicative top-10 obligors
and maximum fixed-rate asset limits for this analysis are 20% and
12.5%, respectively. The transaction also includes various
concentration limits, including a maximum exposure to the
three-largest Fitch-defined industries in the portfolio at 40%.
These covenants ensure that the asset portfolio will not be exposed
to excessive concentration.

Portfolio Management (Neutral): The transaction's reinvestment
period is scheduled to end in January 2024. The weighted average
life covenant has been extended by 12 months to 7.07 years and the
Fitch test matrix will be updated. Fitch's analysis is based on a
stressed-case portfolio with the aim of testing the robustness of
the transaction's structure against its covenants and portfolio
guidelines.

Cash Flow Analysis (Neutral): The weighted-average life (WAL) used
for the transaction's stress portfolio and matrix analysis is 12
months less than the WAL covenant to account for structural and
reinvestment conditions post-reinvestment period, including passing
the over-collateralisation (OC) and Fitch 'CCC' limitation tests
post reinvestment, among others. 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:

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

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

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

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

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

BEST/WORST CASE RATING SCENARIO

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

SUMMARY OF FINANCIAL ADJUSTMENTS

No published financial statements were used in the rating
analysis.

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

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

DATA ADEQUACY

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

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

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

MADISON PARK XIV: Moody's Gives (P)B3 Rating to EUR15.4MM F Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following provisional ratings to refinancing notes to be issued by
Madison Park Euro Funding XIV DAC (the "Issuer"):

EUR324,400,000 Class A Senior Secured Floating Rate Notes due 2032,
Assigned (P)Aaa (sf)

EUR47,700,000 Class B Senior Secured Floating Rate Notes due 2032,
Assigned (P)Aa2 (sf)

EUR37,250,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)A2 (sf)

EUR31,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)Baa3 (sf)

EUR25,750,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)Ba3 (sf)

EUR15,400,000 Class F Senior Secured Deferrable Floating Rate Notes
due 2032, 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.

As part of this refinancing, the Issuer will extend the weighted
average life by one year to 7.07 years. It will also amend the
definition of "Adjusted Weighted Average Rating Factor" and minor
features. In addition, the Issuer will amend the base matrix and
modifiers that Moody's will take into account for the assignment of
the definitive ratings.

The Issuer is a managed cash flow CLO. At least 90% of the
portfolio must consist of secured senior loans or senior secured
bonds and up to 10% of the portfolio may consist of unsecured
senior loans, second-lien loans, high yield bonds and mezzanine
loans. The underlying portfolio is expected to be fully ramped as
of the closing date.

Credit Suisse Asset Management Limited ("CSAM") 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 two-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: EUR515,000,000

Diversity Score: 52

Weighted Average Rating Factor (WARF): 2940

Weighted Average Spread (WAS): 3.5%

Weighted Average Coupon (WAC): 4.00%

Weighted Average Recovery Rate (WARR): 43.50%

Weighted Average Life (WAL): 7.07 years

MILLTOWN PARK: Fitch Raises Class E Notes to 'B+'
-------------------------------------------------
Fitch Ratings has upgraded Milltown Park CLO DAC's class A-2 to E
notes, removed them from Under Criteria Observation (UCO) and
affirmed the class A-1 notes.

     DEBT                RATING            PRIOR
     ----                ------            -----
Milltown Park CLO DAC

A-1 XS1823313843    LT AAAsf   Affirmed    AAAsf
A-2A XS1823314577   LT AA+sf   Upgrade     AAsf
A-2B XS1823315111   LT AA+sf   Upgrade     AAsf
B XS1823315624      LT A+sf    Upgrade     Asf
C XS1823316606      LT BBB+sf  Upgrade     BBBsf
D XS1823317083      LT BB+sf   Upgrade     BBsf
E XS1823317240      LT B+sf    Upgrade     B-sf

TRANSACTION SUMMARY

Milltown Park CLO DAC is a cash flow CLO mostly comprising senior
secured obligations. The transaction is in its reinvestment period
and the portfolio is actively managed by the asset manager.

KEY RATING DRIVERS

CLO Criteria Update: The rating actions mainly reflect the impact
of Fitch's recently updated CLOs and Corporate CDOs Rating Criteria
and the shorter risk horizon incorporated in Fitch's stressed
portfolio analysis. The rating actions are in line with the
model-implied ratings from Fitch's updated stressed portfolio
analysis, which applied the agency's collateral quality matrix
specified in the transaction documentation. When analysing the
matrix, Fitch applied a haircut of 1.5% to the weighted average
recovery rate (WARR) as the calculation of the WARR in transaction
documentation is not in line with the recovery rate assumption in
the latest CLO criteria. The Stable Outlooks reflect Fitch's
expectation that the transaction's performance is likely to remain
stable.

Stable Asset Performance: The transaction's metrics indicate stable
asset performance. The transaction's portfolio notional balance is
currently about 0.7% above its target par. All the reported
collateral quality tests, concentration limitation and coverage
tests are passing. Exposure to assets with a Fitch-derived rating
(FDR) of 'CCC+' and below is around 6% (excluding 1% unrated
assets) and there are no defaults.

'B'/'B-' Credit Quality: Fitch assesses the average credit quality
of the transaction's underlying obligors in the 'B'/'B-' category.
The Fitch weighted average rating factor (WARF) per the latest
criteria is 24.8. The WARF as calculated by the trustee was 33.8,
which is below the maximum covenant of 34.0.

High Recovery Expectation: Senior secured obligations comprise
close to 99% of the portfolio. Fitch views the recovery prospects
for these assets as more favourable than for second-lien, unsecured
and mezzanine assets. The Fitch WARR reported by the trustee was
65.1%, against the covenant at 63.4%.

Diversified Portfolio: The portfolio is well-diversified across
obligors, countries and industries. The top 10 obligor
concentration and the largest obligor represent no more than 13.0%
and 1.5% of the portfolio balance, respectively.

RATING SENSITIVITIES

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

-- Downgrades may occur if build-up of the notes' credit
    enhancement following amortisation does not compensate for a
    larger loss expectation than initially assumed due to
    unexpectedly high levels of defaults and portfolio
    deterioration. Fitch will update the sensitivity scenarios in
    line with the view of its leveraged finance team.

-- A 25% increase of the mean default rate (RDR) across all
    ratings and a 25% decrease in the recovery rate (RRR) across
    all ratings would result in a downgrade of up to three notches
    across the structure, apart from the class A-1 notes, which
    would not be affected.

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

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

-- A 25% decrease of the mean RDR across all ratings and a 25%
    increase of the recovery rate (RRR) across all ratings would
    result in upgrades of up to three notches across the
    structure, except for the class A-1 notes, which are already
    at the highest rating on Fitch's scale and cannot be upgraded.

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.

SUMMARY OF FINANCIAL ADJUSTMENTS

No financial statement data has been received

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

Milltown Park CLO DAC

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

The majority of the underlying assets or risk presenting entities
have ratings or credit opinions from Fitch and/or other Nationally
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.

PENTA CLO 8: Moody's Assigns B3 Rating to EUR11.4MM Class F Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to refinancing notes issued by Penta
CLO 8 Designated Activity Company (the "Issuer"):

EUR215,250,000 Class A Senior Secured Floating Rate Notes due
2034, Definitive Rating Assigned Aaa (sf)

EUR24,000,000 Class B-1 Senior Secured Floating Rate Notes due
2034, Definitive Rating Assigned Aa2 (sf)

EUR11,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2034,
Definitive Rating Assigned Aa2 (sf)

EUR21,850,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned A2 (sf)

EUR24,500,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned Baa3 (sf)

EUR17,500,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2034, Definitive Rating Assigned Ba3 (sf)

EUR11,400,000 Class F 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 will extend the weighted average
life to 8.0 years and amend 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 senior secured obligations and at least
70% of the portfolio must consist of senior secured loans.

Therefore, up to 7.5% of the portfolio may consist of senior
unsecured obligations, second-lien loans, mezzanine obligations and
high yield bonds. The portfolio is fully ramped as of the closing
date.

Partners Group (UK) Management Ltd ("Partners Group") 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
two 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 seven classes of notes rated by Moody's, the
Issuer had issued EUR32,700,000 Subordinated Notes due 2034, 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: EUR350,000,000

Diversity Score: 40

Weighted Average Rating Factor (WARF): 3150

Weighted Average Spread (WAS): 3.65%

Weighted Average Coupon (WAC): 5.5%

Weighted Average Recovery Rate (WARR): 45.9%

Weighted Average Life (WAL): 8.0 years

PENTA CLO 8: S&P Assigns B- (sf) Rating to Class F-R Notes
----------------------------------------------------------
S&P Global Ratings assigned its credit ratings to Penta CLO 8 DAC's
class A-R to D-R notes.

On Dec. 8, 2021, the issuer refinanced the original class A to F
notes by issuing replacement notes with different notional pursuant
to an optional redemption in whole of the existing notes.

The replacement notes are largely subject to the same terms and
conditions as the original notes, except for the following:

-- The replacement notes have a lower margin and spread over Euro
Interbank Offered Rate (EURIBOR) than the original notes, except
for the class F-R notes, which have a higher spread over EURIBOR.

-- As the issuance amounts of the replacement notes differ from
the original issuance, the levels of credit enhancement have also
changed.

-- The non-call period has been extended by 15 months.

The ratings assigned to Penta 8 CLO DAC's refinanced notes reflect
S&P's 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 are in line with S&P's
counterparty rating framework for rating liabilities up to 'AAA'.

-- Under the transaction documents, the rated notes will pay
quarterly interest unless there is a frequency switch event.
Following this, the notes will permanently switch to semiannual
payment.

-- The portfolio's reinvestment period will end in January 2024.

S&P said, "In our cash flow analysis, we used a EUR350.00 million
adjusted collateral principal amount, a weighted-average spread of
3.65%, the reference weighted-average coupon (5.50%), and the
actual weighted-average recovery rates for all rating levels,
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.

"Our credit and cash flow analysis indicates that the available
credit enhancement for the class B-1-R to D-R notes could withstand
stresses commensurate with higher ratings than those we have
assigned. However, as the CLO is in its reinvestment phase, during
which the transaction's credit risk profile could deteriorate, we
have capped our assigned ratings on the notes. In our view the
portfolio is granular in nature, and well-diversified across
obligors, industries, and assets."

Bank of New York Mellon (London Branch) is the bank account
provider and custodian. The documented counterparty replacement and
remedy mechanisms are in line with S&P's current counterparty
criteria to rate liabilities up to 'AAA'.

S&P said, "Following the application of our structured finance
sovereign risk criteria, we consider the transaction's exposure to
country risk to be limited at the assigned ratings, as the exposure
to individual sovereigns does not exceed the diversification
thresholds outlined in our criteria.

"At closing, the transaction's legal structure is bankruptcy
remote, in line with our legal criteria.

"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 the class
A-R to F-R 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): tobacco, controversial weapons, and thermal
coal and fossil fuels from unconventional sources. 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."

The transaction securitizes a portfolio of primarily senior-secured
leveraged loans and bonds, and it is managed by Partners Group (UK)
Management Ltd.

Ratings List

CLASS  RATING    AMOUNT   REPLACEMENT     ORIGINAL      SUB(%)
                 (MIL. EUR)  NOTES           NOTES
                             INTEREST RATE*  INTEREST RATE

A-R    AAA (sf)  215.25  3-month EURIBOR  3-month EURIBOR  38.50  
                      
                             plus 0.82%      plus 1.15%  

B-1-R  AA (sf)    24.00  3-month EURIBOR  3-month EURIBOR  28.50
                             plus 1.78%      plus 1.95%

B-2-R  AA (sf)    11.00       2.00%           2.05%        28.50

C-R    A (sf)     21.85  3-month EURIBOR  3-month EURIBOR  22.26
                             plus 2.15%       plus 2.80%

D-R    BBB- (sf)  24.50  3-month EURIBOR  3-month EURIBOR  15.26
                             plus 3.25%      plus 4.25%

E-R    BB- (sf)   17.50  3-month EURIBOR  3-month EURIBOR  10.26
                             plus 5.93%      plus 6.70%

F-R    B- (sf)    11.40  3-month EURIBOR  3-month EURIBOR   7.00
                             plus 8.66%      plus 8.15%

*The payment frequency switches to semiannual and the index
switches to six-month EURIBOR when a frequency switch event occurs.

EURIBOR--Euro Interbank Offered Rate.

ROS AOIBHINN: Enters Liquidation, Now Under HSE Stewardship
-----------------------------------------------------------
Simon Bourke at Independent.ie reports that Ros Aoibhinn Nursing
Home has gone into liquidation and is now under the stewardship of
the HSE while residents are relocated.

The HSE/South East Community Healthcare was notified last week by
the Health Information and Quality Authority (HIQA) of its plans to
cancel the registration of the Ros Aoibhinn private nursing home in
Bunclody, Co. Wexford, Independent.ie relates.

According to Independent.ie, on Dec. 3, the HSE became the
temporary registered provider at Ros Aoibhinn as part of a role to
make alternative, long-term arrangements in appropriate settings
for its residents.

A meeting of the Ros Aoibhinn creditors has been scheduled for Dec.
14, Independent.ie discloses.




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

BANCA POPOLARE: DBRS Assigns BB Subordinated Debt Rating
--------------------------------------------------------
DBRS Ratings GmbH confirmed the ratings of Banca Popolare di
Sondrio S.C.p.A. (BPS or the Bank), including the Long-Term Issuer
Rating of BBB (low) and the Short-Term Issuer rating of R-2
(middle). The Bank's Deposit ratings were confirmed at BBB/R-2
(high), one notch above the IA, reflecting the legal framework in
place in Italy, which has full depositor preference in bank
insolvency and resolution proceedings. The trend on all ratings has
been revised to Stable, from Negative. In addition, DBRS
Morningstar also assigned a subordinated debt rating of "BB" with
Stable Trend. DBRS Morningstar expects that any future issuance by
BPS of Subordinated Debt would be rated at this level. The "BB"
rating is two notches below BPS's Long-Term Issuer Rating and
Long-Term Senior Debt rating, in line with the Framework set out in
DBRS Morningstar's "Global Methodology for Rating Banks and Banking
Organisations", dated July 19, 2021. DBRS Morningstar has also
maintained the Intrinsic Assessment (IA) at BBB (low) and the
Support Assessment at SA3.

KEY RATING CONSIDERATIONS

The change of the trend to Stable reflects our view that BPS has
successfully managed through the economic disruption caused by the
COVID-19 pandemic, boosted by the reduction in Non-Performing Loans
(NPLs) since 2020, and the good coverage ratios. DBRS Morningstar
views BPS as being well placed to absorb any potential asset
quality deterioration that could be driven by the ending of the
support provided by the moratoria schemes. In addition, the change
in the trend takes into account the improved earnings in recent
periods.

The confirmation of the ratings takes into account the Group's
improved asset quality profile, evidenced by the lower stock of
non-performing exposures (NPEs), following the securitization of
around EUR 1.4 billion of NPLs in 2020. The ratings also
incorporate the Bank's relatively small national position but solid
franchise in the Lombardy region, especially in the province of
Sondrio. BPS also has a long and proven earnings track record and a
robust retail funding base. In addition, the ratings are
underpinned by BPS's ample capital buffers above supervisory
requirements.

Nonetheless, the ratings still take into account the Bank's modest,
albeit resilient, profitability, the still high levels of NPEs
compared to the European average and potential challenges
associated with the Bank's pending legal transformation into a
joint-stock company by end-2021.

RATING DRIVERS

An upgrade of the ratings would require a further reduction in the
NPE stock while maintaining solid capital levels, as well as a
sustained improvement in profitability levels.

A sustained deterioration in asset quality or profitability levels
would lead to a downgrade of the ratings.

RATING RATIONALE

Franchise Combined Building Block (BB) Assessment: Moderate/Weak

BPS is a medium-sized mutual bank (Banca Popolare) focused on
retail and commercial banking. Based in Sondrio (Lombardy), the
Bank had EUR 53.3 billion in total assets as of end-September 2021
and 370 branches, primarily in Northern Italy. Outside Italy, BPS
has a small presence in retail and commercial banking in
neighboring Switzerland. BPS is the market leader for loans and
deposits in the small province of Sondrio. However, the Bank's
national market shares are more modest at around 2%. In addition,
BPS has a leading market position in Italy in the public
administration payment systems. BPS's legal structure is expected
to be transformed into a joint-stock company by end-2021 as per the
Italian law for the reform of the mutual banking sector, which was
confirmed by the Italian State Council and the European Court of
Justice.

Earnings Combined Building Block (BB) Assessment: Moderate/Weak

BPS's profitability deteriorated in 2020 due to the low interest
rate environment and the high cost of risk stemming from the
COVID-19 related provisioning costs. However, profitability metrics
have now returned closer to pre-pandemic levels, in particular
through a lower cost of risk. BPS will continue to face earnings
challenges stemming from the low interest rate environment and
possible asset quality deterioration. BPS reported net attributable
income of EUR 201.5 million in 9M 2021 compared to EUR 64.5 million
9M 2020. This was mainly driven by much higher revenues and lower
provisions despite higher operating expenses. Total revenues
increased 23.5% YoY, primarily due to higher results from financial
operations as compared to 9M 2020. Operating expenses remained well
controlled YoY and the cost-income ratio improved to 53.4% in 9M
2021 from 64.1% for the same period a year ago. Loan loss
provisions (LLP) declined over 50% in 9M 2021 YoY to EUR 91.2
million compared to EUR 140.6 million, absorbing 23% of Income
before Provisions and Taxes (IBPT). The Bank's cost of risk stood
at 40 bps in 9M 2021 as compared to 65 bps in 9M 2020.

Risk Combined Building Block (BB) Assessment: Moderate/Weak

BPS's asset quality has improved in 2020 and 9M 2021 following two
securitizations totaling EUR 1.4 billion. As a result, the total
stock of gross non-performing exposures (NPEs) decreased to EUR 2.2
billion at end-September 2021 from EUR 3.7 billion at end-2019 and
the gross NPE ratio improved to 7.0% from 12.6% at end-2019. We
expect the Bank to execute similar securitizations in the near
future. While asset quality remains weaker compared to some other
European banks, we view the reduction in legacy NPEs as providing
headway to absorb the potential asset quality deterioration
stemming from the end of support measures.

Funding and Liquidity Combined Building Block (BB) Assessment:
Good/Moderate

The Bank has a solid funding and liquidity position, underpinned by
its large and stable retail deposit franchise. At end-September
2021, customer deposits accounted for 71% of the bank's total
funding. This has reduced from the 80% level at end-2019, mainly
due to the increase in central bank deposits, especially TLTRO 3
funding amid the COVID-19 crisis. At end-September 2021, the Bank
's liquidity coverage ratio (LCR) and net stable funding ratio
(NSFR) were well above regulatory requirements.

Capitalization Combined Building Block (BB) Assessment: Moderate

DBRS Morningstar views the Bank's capital as remaining pressured by
the large, albeit reduced, stock of unreserved NPEs but considers
the Bank to have ample cushions over minimum regulatory
requirements. The CET1 ratio (fully loaded) was 16.4% at
end-September 2021 up modestly from 16.3% at end-2020. The fully
loaded total capital ratio stood at 18.2% at end-September 2021
compared to 18.7% at end-2020, and the phased-in CET1 ratio was
16.5% and the phased-in total capital ratio stood at 18.3% at
end-September 2021. We view positively that BPS maintains an ample
buffer above its regulatory minimum capital requirements, including
784 bps above the CET1 and 483 bps over the Total Capital
requirements.

Notes: All figures are in EUR unless otherwise noted.


ICCREA BANCA: DBRS Confirms BB(high) LongTerm Issuer Rating
-----------------------------------------------------------
DBRS Ratings GmbH confirmed the ratings of Iccrea Banca SpA (Iccrea
or the Bank), including the Long-Term Issuer Rating of BB (high)
and the Short-Term Issuer Rating of R-3. Concurrently, DBRS
Morningstar confirmed the Bank's Deposit ratings at BBB (low)/R-2
(middle), which is one notch above the Intrinsic Assessment (IA),
reflecting the legal framework in place in Italy which has full
depositor preference in bank insolvency and resolution proceedings.
The trend on all ratings is Stable. The Bank's IA is BB (high)
while the Support Assessment is SA3

KEY RATING CONSIDERATIONS

The confirmation of the ratings and the Stable trend takes into
account Iccrea's key role as the central entity of Gruppo Bancario
Cooperativo Iccrea (GBCI or the Group), the largest Italian
cooperative banking group, its strong retail funding base
underpinned by the stable access to the cooperative member banks'
(BCC) customer network, as well as the Group's adequate capital
position. In addition, DBRS Morningstar notes that the Group is
making progress in reducing its large stock of legacy
non-performing loans (NPLs) and simplifying its structure. These
put the Group in a stronger position to withstand the expected
asset quality deterioration due to COVID-19.

At the same time, we continue to view the Group's profitability as
modest considering the low contribution from fee income, modest
operating efficiency, and high loan loss provisions. In our view,
the Group's ongoing de-risking plan will likely keep the cost of
risk high in the near term.

RATING DRIVERS

An upgrade would require further improvements in asset quality
while preserving adequate capital buffers. A sustained improvement
in profitability would be also credited positive.

A downgrade would occur in the event of a significant formation of
new NPLs or the weakening of the capital buffers.

RATING RATIONALE

Franchise Combined Building Block (BB) Assessment: Good/Moderate

Formed in March 2019, the Group is the largest cooperative network
in Italy with 128 small cooperative banks as of October 2021 and
total combined assets of around EUR 175 billion at the end-June
2021. The Group has an extensive domestic footprint with over 2,500
branches and around 22,000 employees evenly distributed across
Italy, serving over 3 million, mostly households and SME customers.
Iccrea and the cooperative banks are tied by a cohesion agreement
which creates a framework for more effective coordination and
better controls within the Group as well as the potential for more
consolidation and simplification of its complex structure.

Earnings Combined Building Block (BB) Assessment: Weak

We continue to view GBCI's profitability as constrained by the low
interest rate environment, the low contribution from
diversification and fee-based income, as well as the modest
operating efficiency and high loan loss provisions. In H1 2021 the
Group reported net attributable income of EUR 400 million, up from
EUR 122 million in H1 2020, and a Return on Equity (ROE) of 7.5% in
H1 2021, up from 2.4% in H1 2020. The increase was largely due to
higher revenues due to the large take-up of TLTRO 3 funds, lower
funding costs and significant one-off gains from the sale of
Italian government bonds and equity shareholdings. The
cost-to-income ratio improved to 65.7% in H1 2021 from 71.6% in the
same period last year, as calculated by DBRS Morningstar, despite
operating expenses rising by 5% YoY. In H1 2021, GBCI's annualized
cost of risk remained unchanged YoY at 90 bps. In the near term,
DRBS Morningstar expects impairment provisions to be elevated,
given the ongoing NPL reduction plan, as well as the additional
provisioning identified by the ECB under the Asset Quality Review
(AQR) concluded in July 2021.

Risk Combined Building Block (BB) Assessment: Weak/Very Weak

The Group's risk profile remains challenged, mostly impacted by a
still large, albeit reducing, stock of NPLs. As of end-June 2021,
GBCI reported EUR 8.3 billion in gross NPLs, down by 22% YoY,
corresponding to a gross NPL ratio of 8.9% (or 4% net of
provisions). We expect GBCI to make further process in reducing its
stock of legacy NPLs via securitizations and disposals, although we
would expect some impact on asset quality from the pandemic. The
Group targets a reduction in the stock of gross NPLs to around EUR
6 billion by the end of 2023, which would imply gross and net NPL
ratios falling to around 6.5% and 3.3% respectively, based on a
total NPL coverage of 51%. As part of this plan, in November 2021
GBCI announced a NPL securitization of EUR 1.3 billion using the
GACS scheme.

Thus far, the level of new NPL inflows from the pandemic has been
contained. The stock of loans under moratoria fell to around 7% of
the Group's total net customer loans as of September 2021, down
from the peak of 26% one year earlier. Around 1.7% were classified
as Stage 3 as of end-June 2021. At the same time, State-guaranteed
loans provided by the Group were EUR 8.5 billion, accounting for
around 10% of GBCI's net customer loans, up from 2% in H1 2020.

Funding and Liquidity Combined Building Block (BB) Assessment:
Good/Moderate

The Group maintains a stable funding position, mainly supported by
the large retail deposit base of the BCC's network. Access to the
wholesale market is centralized via Iccrea Banca. In H1 2021, the
Group had around EUR 103 billion in customer deposits (or 65% of
GBCI's funding mix), up 14% YoY, mainly due to lower household
consumption and higher corporate deposit inflows. Households remain
the largest contributor to GBCI's deposit base, accounting for
around 62% of the total. The Group continued to increase its
exposure to the ECB and at end-June 2021 this accounted for 21% of
total funding. With the aim to fulfil its MREL minimum
requirements, the Bank issued a EUR 300 million Tier 2 subordinated
bond in October 2021 and its inaugural Social Senior Preferred Bond
(EUR 500 million) in November 2021. This falls within the Bank's
plans to issue around EUR 3.6 billion of MREL-eligible liabilities
in 2021-2023. In addition, the Bank also issued EUR 500 million of
covered bonds.

Capitalization Combined Building Block (BB) Assessment: Moderate

GBCI's capitalization benefitted from the recent progress in the
de-risking process, the supply of State-guaranteed loans, and the
issuance of subordinated instruments. However, the Group's capital
position is constrained by the still high level of unreserved NPLs
and modest internal capital generation. In H1 2021, GBCI reported
its phased-in CET1 and Total Capital ratios, excluding the net
income of the period as well as the recent Tier 2 issuance, at
16.5% and 17.2% respectively, up from 16.1% and 16.9% one year
earlier, but down slightly compared to the 16.7% and 17.5% ratios
at end-2020. The slight reduction in H1 2021 was mainly driven by
the reduction in the phased-in positive impact as IFRS 9 continues
to unfold. On a fully-loaded basis, the Group's CET1 and Total
Capital ratios stood at 15.4% and 16.1% respectively at end-June
2021. As a result, capital buffers over SREP minimum requirements
were reported at 700 bps and 420 bps respectively for CET1 and
Total Capital, excluding the ECB's temporary flexibility regime, as
well as the opportunity to partly fulfill the Pillar 2 Requirement
(P2R) by CET1 Capital.

Notes: All figures are in EUR unless otherwise noted.


IGD SIIQ: S&P Alters Outlook to Stable, Affirms 'BB+' Ratings
-------------------------------------------------------------
S&P Global Ratings revised its outlook on IGD Siiq SpA (IGD) to
stable from negative and affirmed its 'BB+' ratings on the company
and its debt, as well as maintaining the recovery rating at '3'
(65% estimated recovery).

The stable outlook reflects S&P's view that the successful disposal
of non-strategic stand-alone hypermarkets and supermarkets should
help IGD to maintain its debt-to-debt plus equity ratio at 45%-46%
in the coming 12 months, while its cash flow generation should
benefit from the progressive reopening of its shopping malls and
translate into an EBITDA interest coverage of 3x-4x and debt to
EBITDA of about 9x-10x.

IGD's asset disposal should allow the company to improve its debt
to debt plus equity to 45%-46%. On Nov. 25, 2021, IGD closed the
sale of a portfolio of non-strategic stand-alone hypermarkets and
supermarkets valued at EUR140 million. The portfolio consisted of
five hypermarkets and one supermarket generating net operating
income of EUR7.7 million per year. The company entered into an
agreement with Intermediate Capital Group (ICG) in which all
properties were transferred to a closed vehicle managed by Savills.
IGD will retain a 40% stake in the vehicle, but with subordinated
rights, and will keep the property management. As a result of the
transaction, IGD received about EUR115 million, which will be used
to strengthen the company's balance sheet and to cover upcoming
debt maturities in 2022 of around EUR175 million. S&P said,
"Therefore, we forecast debt to debt plus equity will be at 45%-46%
in the coming 12 months (versus 50.0% on June 30, 2021), well below
our downside scenario trigger. Our base case incorporates potential
slight declines in asset values of up to 2.5% in 2021 and up to 1%
in 2022. IGD reported generally flat valuation movements (0.10%
excluding leasehold properties) in its portfolio as of June 30,
2021."

The progressive reopening of shopping malls should benefit EBITDA
generation. After a rough first half of the year because of
restrictions and variable closures in its shopping malls, IGD has
benefited in the second half from the reopening of all its assets.
Tenant sales recovered strongly during the third quarter and stood
at 0.2% and 15.1% in September and October 2021 compared with 2019
levels (-46.1% in March and -36.0% in April). That said, footfall
continues to lag 2019 levels because certain restrictions on malls'
capacity still apply (footfall levels in October were 89.5% versus
2019). S&P said, "We note that the company's occupancy has also
improved by 1.14% in Italy to 95.40% compared with year-end 2020,
and that rent collection stands at 86% in Italy, which is about the
same as last year. We therefore expect IGD's adjusted EBITDA to be
similar to last year's (EUR98.3 million). Thereafter, assuming no
significant disruption in its operating environment, we expect a
progressive recovery in its EBITDA up to 10% at constant perimeter.
This would translate into EBITDA interest coverage between 3x-4x
and debt to EBITDA at 9x-10x in the coming 12 months (these ratios
were 3.2x and 11.8x at year-end 2020). That said, we will continue
to monitor how the surge in COVID-19 cases across Europe and the
new omicron variant could potentially affect IGD's cash flow
recovery."

The disposal will strengthen IGD's financial risk profile but could
affect the stability of its rental income. Pro forma market values
on June 30, 2021, IGD's exposure to hypermarkets and supermarkets
will reduce to 19.4% of the total portfolio value from 24.8% and
(to 21.3% in terms of revenue as of Sept. 30, 2021, from 25.8%).
S&P said, "We believe that the reduction in the hypermarket and
supermarket exposure could increase the instability of IGD's rental
income. These assets remained resilient throughout the pandemic
with no disruption in rent collection and benefited from very long
leases, with an average residual maturity of 14.2 years as of Sept.
30, 2021. That said, we understand that these assets were non-core
to IGD, given they were stand-alone assets. IGD focuses on and
obtains higher returns from assets where it owns the hypermarket or
supermarket together with the adjacent shopping mall. We don't
expect the company to divest significant additional parts of this
portfolio, which we continue to view as a strength in our business
assessment."

S&P said, "We expect IGD to maintain adequate liquidity and address
its maturities in a timely manner. We understand that the sale
proceeds, together with IGD's cash balance (EUR53.9 million on
Sept. 30, 2021) and its back up facilities (EUR60 million undrawn
on the same date), could cover the upcoming maturities in 2022
(about EUR175 million). Cash flow generation and IGD's limited
committed capex of around EUR20 million should allow the company to
keep its ratio of liquidity sources to uses above 1.2x in the 12
months started Oct. 1, 2021. That said, IGD will face around EUR275
million of bank debt maturities in 2023, together with the expiry
of its EUR60 million back-up facilities. We expect that the company
will address them in a timely manner to maintain adequate
liquidity, meaning that the ratio of secured liquidity sources to
uses will always be above 1.2x for the next 12 months.

"The asset sale will not affect our recovery and issue ratings.
IGD's unsecured lenders continue to benefit from a robust asset
base valued at EUR2.3 billion, a relatively low loan to value
(48.3% on Sept. 30, 2021), and a capital structure that includes
limited secured debt (24% of total debt). Despite the reduction in
the asset base, our estimate of recovery prospects continues to be
healthy. That said, we continue to view Italy's jurisdiction as
weaker than that of Germany or the U.K. Hence, we cap our recovery
rating at '3' and we expect meaningful recovery (50%-70%; rounded
estimate: 65%) for IGD's unsecured lenders."

S&P Global Ratings believes the new omicron variant is a stark
reminder that the COVID-19 pandemic is far from over. Although
already declared a variant of concern by the World Health
Organization, uncertainty still surrounds its transmissibility,
severity, and the effectiveness of existing vaccines against it.
Early evidence points toward faster transmissibility, which has led
many countries to close their borders with Southern Africa or
reimpose international travel restrictions. S&P said, "Over coming
weeks, we expect additional evidence and testing will show the
extent of the danger it poses to enable us to make a more informed
assessment of the risks to credit. Meanwhile, we can expect a
precautionary stance in markets, as well as governments to put into
place short-term containment measures. Nevertheless, we believe
this shows that, once again, more coordinated, and decisive efforts
are needed to vaccinate the world's population to prevent the
emergence of new, more dangerous variants."

S&P said, "The stable outlook reflects our view that the successful
disposal of non-strategic stand-alone hypermarkets and supermarkets
should help IGD maintain its debt-to-debt plus equity ratio at
45%-46% in the coming 12 months. At the same time, its cash flow
generation should benefit from the progressive re-opening of its
shopping malls and should translate into an EBITDA interest
coverage of 3x-4x and debt to EBITDA of about 9x-10x in the same
period."

S&P could consider a negative rating action if:

-- IGD's operating performance is severely impacted again by the
closure of shops in Italy or potential bankruptcies of its retail
tenants;

-- Debt to debt plus equity increases well above 50%;

-- Debt to EBITDA deteriorates above 13x;

-- EBITDA interest coverage decreases to 2.4x; or

-- The company failed to address its upcoming maturities in a
timely manner, decreasing its liquidity cushion.

S&P would consider a positive rating action if:

-- IGD shows more resilience to the challenging retail and macro
environment in Italy, generating positive like-for-like rental
growth, maintaining high occupancy levels, and obtaining positive
valuations in its portfolio;

-- Debt to debt plus equity decreases below 40%;

-- Debt to EBITDA improves well below 9.5x; and

-- EBITDA interest coverage remains well above 3x.


MAGGESE SRL: DBRS Lowers Class A Notes Rating to CCC(high)
----------------------------------------------------------
DBRS Ratings GmbH downgraded its rating on the Class A notes issued
by Maggese S.r.l. (the Issuer) to CCC (high) (sf) from BBB (low)
(sf). The trend remains Negative.

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 July
25, 2037. DBRS Morningstar does not rate the Class B or Class J
notes.

At issuance, the Notes were backed by a EUR 697 million portfolio
by gross book value consisting of a mixed pool of Italian
nonperforming residential, commercial, and unsecured loans
originated by Cassa di Risparmio di Asti S.p.A. and Cassa di
Risparmio di Biella e Vercelli - Biverbanca S.p.A.

The receivables are serviced by Prelios Credit Servicing S.p.A.
(the Servicer). A backup servicer facilitator, Securitization
Services S.p.A., was appointed and will act as a servicer if the
appointment of Prelios Credit Servicing S.p.A. is terminated.

RATING RATIONALE

The rating downgrade follows a review of the transaction and is
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; (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 initial expectations.

-- Portfolio characteristics: loan pool composition as of
September 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 July 2021 payment report, the cumulative collection ratio is
60% and the net present value cumulative profitability ratio is
99%. Since the January 2021 interest payment date, the 90% limit
for the cumulative collection ratio has been breached, so that
Class B interest payments are subordinated to the repayment of the
Class A principal.

-- 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 target amount is equal to 4% of the Class A notes principal
outstanding and is currently fully funded.

TRANSACTION AND PERFORMANCE

According to the latest payment report from July 2021, the
outstanding principal amounts of the Class A, Class B, and Class J
notes were EUR 115.1 million, EUR 24.4 million, and EUR 11.4
million, respectively. The balance of the Class A notes has
amortized by approximately 32.6% since issuance. The current
aggregated transaction balance is EUR 150.9 million.

As of June 2021, the transaction was performing significantly below
the Servicer's business plan expectations. The actual cumulative
gross collections equaled EUR 72.7 million whereas the Servicer's
business plan estimated cumulative gross collections of EUR 125.0
million for the same period. Therefore, as of June 2021, the
transaction was underperforming by EUR 52.3 million (-41.8%)
compared with the initial business plan expectations.

At issuance, DBRS Morningstar estimated cumulative gross
collections for the same period of EUR 103.8 million at the BBB
(low) (sf) stressed scenario. Therefore, as of June 2021, the
transaction was performing considerably below DBRS Morningstar's
stressed expectations at issuance.

Pursuant to the requirements set out in the receivable servicing
agreement, in April 2021, the Servicer delivered an updated
portfolio business plan.

The updated portfolio business plan, combined with the actual
cumulative gross collections of EUR 64.8 million as of 31 December
2020, results in a total of EUR 212.5 million, which is 13.3% lower
than the total gross disposition proceeds of EUR 245.1 million
estimated in the initial business plan, and expected to be realized
over a longer period of time. The servicer has been underperforming
its updated business plan in the past quarters. The updated DBRS
Morningstar CCC (high) (sf) rating stress assumes a haircut of 2.1%
to the Servicer's updated business plan, considering total expected
collections.

Without including actual collections, the Servicer's expected
future collections from July 2021 now account for EUR 134.5 million
over a considerably longer time period than initially expected.
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 July 2037.

DBRS Morningstar analyzed the transaction structure using Intex
DealMaker.

The coronavirus 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 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.


ROSSINI SARL: Moody's Affirms 'B2' CFR on EUSA Pharma Transaction
-----------------------------------------------------------------
Moody's Investors Service affirmed the B2 corporate family rating
and B2-PD probability of default rating of Rossini S.a r.l
(Rossini), following the announcement by Recordati S.p.A.
(Recordati), its 52%-owned subsidiary, of the acquisition of EUSA
Pharma (UK) Ltd (EUSA). At the same time, Moody's also affirmed the
B3 rating of Rossini's senior secured notes. The outlook remains
stable.

RATINGS RATIONALE

The affirmation of Rossini's B2 CFR reflects Moody's expectation
that the increase in leverage related to the debt funded EUSA
acquisition will be temporary and that, by the end of 2023,
Rossini's credit metrics will return to pre-acquisition levels. It
also considers some positive effects of the acquisition on
Recordati's business profile and the confirmation that Rossini will
continue to receive from Recordati a dividend that will enable it
to cover the interest on its EUR1.3 billion senior secured notes.
The B2 rating will nevertheless be weakly positioned after the
acquisition, which will not leave much flexibility for additional
M&A activity.

On December 3, 2021, Recordati, which is majority-owned by Rossini
and Rossini's sole asset, announced the signing of a share purchase
agreement to acquire EUSA, a UK pharmaceutical company specialised
in rare and niche oncology diseases for an enterprise value of
EUR750 million. The acquisition will enhance Recordati's rare
disease franchise with the addition of two main products, Qarziba
(oncology) and Sylvant (immunology), which are both biological
drugs with EU orphan drug designation and have good growth
prospects. The acquisition bears some execution risks, including
the retention of EUSA's expertise on its products, the successful
implementation of a technical transfer that is ongoing at EUSA, and
the future approval of Qarziba in the US.

Recordati has estimated that EUSA will add annual revenue of EUR150
million and EBITDA of EUR50 million by 2023 and that peak sales of
EUSA's products will reach EUR250 million. The transaction will be
funded with a EUR650 million bridge facility and cash available and
is expected to close during H1 2022, subject to regulatory
clearances. Moody's estimates that Rossini's pro forma leverage
(Moody's-adjusted debt/EBITDA) will increase to up to around 4.9x
from 4.1x, based on its 2021 projections and on a full
consolidation of Recordati. Moody's projects that adjusted leverage
will increase to around 6.8x from 6.0x, based on a proportionate
consolidation of Recordati and that leverage will be back to
pre-acquisition levels by 2023. The acquisition of EUSA is in line
with Recordati's strategy to grow its rare disease segment both
organically and inorganically. Recordati confirmed that
post-acquisition, it will continue to pay a dividend representing
about 60% of its reported consolidated net income, a level that
will enable Rossini to cover its expenses, which primarily include
the service of its EUR1.3 billion senior secured notes' interest.
Moody's regards the company's financial strategy and risk
management as a governance consideration under its ESG framework.

Rossini's B2 CFR continues to reflect Recordati's good product
diversification and presence in the profitable rare disease
segment; sound free cash flow (FCF) generation at Recordati,
underpinned by high margin and an ability to limit earnings erosion
after patent expiries; and good liquidity at Rossini. The B2 CFR
also considers the company's complex financial structure, as
Rossini does not own pharmaceutical operations and relies on
Recordati's dividend to service its debt; a large debt load, with
an additional EUR781 million of deferred payment notes residing
outside the restricted group; M&A risk at Recordati's level; the
relatively small scale of Recordati compared with industry peers.

RATIONALE FOR THE OUTLOOK

The stable outlook reflects Moody's expectation that after the
acquisition of EUSA, credit metrics will return to pre-acquisition
levels by 2023, supported by earnings growth at Recordati, and that
debt-funded M&A activity will meanwhile remain limited.

LIQUIDITY

The liquidity of Rossini is good. Rossini had EUR76 million of cash
on balance sheet as of September 30, 2021 and access to a EUR195
million undrawn revolving credit facility (RCF). In addition,
Moody's expects that Recordati will continue to generate solid cash
flow, which will allow it to pay a dividend around EUR120 million
in the next 12 months. This will be sufficient to pay the coupon of
the EUR1.3 billion senior secured notes, which absorbs about EUR70
million of cash per year, and to pay a dividend of about EUR16
million, which covers the cash interest on the deferred payment
notes. There are no short-term debt maturities because the notes
will mature in 2025. Rossini's RCF contains a springing covenant
with ample capacity, tested if drawings exceed EUR150 million.

ESG CONSIDERATIONS

Governance is the most important consideration because Rossini
relies on Recordati's dividend to service its debt. With its
majority ownership, Rossini controls Recordati's board and its
dividend policy, but failing to maintain control over this
subsidiary would markedly deteriorate Rossini's credit quality. As
is customary of private equity-owned companies, Rossini has a high
tolerance for leverage.

Moody's views social risk as high for pharmaceutical companies. As
rising healthcare spending strains government budgets, the strain
on drug prices and reimbursement levels continues to increase.
However, Recordati's largest market is Europe, where prices are
already quite low, unlike the US. Moody's assessment of social risk
also considers the litigations that pharmaceutical companies face,
which are currently minor for Recordati.

STRUCTURAL CONSIDERATIONS

Rossini's debt structure comprises a EUR195 million super senior
RCF maturing in April 2025, and EUR650 million of senior secured
fixed rate notes and EUR650 million of senior secured floating-rate
notes, both maturing in October 2025. The senior secured notes do
not benefit from a guarantee from Recordati. Moody's loss-given
default model also considers the debt at Recordati, which amounted
to EUR1.1 billion as of September 2021, to which the EUR650 million
bridge loan to fund the EUSA acquisition will be added, increasing
structural subordination of the Rossini notes. Despite the increase
in structural subordination, Moody's continues to rate the senior
secured notes B3, one notch below the corporate family rating, but
cautions that additional debt at Recordati would likely result in a
widening of the notching.

The B2-PD PDR reflects a 50% recovery rate appropriate for a debt
structure comprising bonds and loans. Deferred payment notes of
EUR781 million as of September 30, 2021 reside outside the
restricted group, at Rossini Investments' level. Moody's does not
include these instruments in Rossini's Moody's-adjusted debt
calculation and in its recovery analysis but factors them
qualitatively in its analysis of the group's credit quality.

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

Rossini's ratings could be upgraded if (i) its proportionally
consolidated debt/EBITDA trends towards 5.0x and (ii) Recordati
maintains sustained earnings and FCF growth at a level in line with
that in recent years.

Rossini's ratings could be downgraded if (i) its proportionally
consolidated debt/EBITDA remains above 6.0x for a prolonged period;
(ii) it is unable to maintain a ratio of dividend
received/financial and operating expenses of around 1.5x; or (iii)
it fails to maintain its control over Recordati's dividend policy.
A downgrade could also take place if Recordati's operating
performance weakens, as illustrated, for instance, by a decline in
its revenue, earnings or FCF. A further increase in Recordati's
debt, which would amplify the structural subordination of debt at
Rossini, could lead to a downgrade of the rating on the notes
issued at Rossini's level.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Pharmaceuticals
published in November 2021.

COMPANY PROFILE

Rossini S.a r.l (Rossini) is a holding company set up by a
consortium of funds led by CVC Capital Partners which owns a 52%
stake in Recordati S.p.A. (Recordati). Founded in 1926, Recordati
is an Italian pharmaceutical company, which generated EUR1.4
billion of revenue in 2020. It focuses on four therapeutic areas:
cardiovascular system; alimentary tract and metabolism;
genitourinary system; and respiratory system. Recordati also
produces and distributes over-the-counter products and operates in
other therapeutic areas, mainly with local brands and product.



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

KAP: Uniprom to Gradually Close Down Aluminium Smelter
------------------------------------------------------
Radomir Ralev at SeeNews reports that Montenegro's Uniprom plans to
gradually close down aluminium smelter KAP due to the unfavourable
price of electricity that will come into force as of Jan. 1,
Uniprom owner and CEO Veselin Pejovic said.

"Just at the moment when the price of aluminum is very favourable
on the market, unfortunately I must say that some people did
everything for me to announce that KAP is closing," Mr. Pejovic, as
cited by SeeNews, said on Dec. 8, according to a video file posted
on the website of public broadcaster RTCG.

He said the planned shutdown of the smelter will begin on Dec. 15,
SeeNews notes.

"We are concerned, in the first place, about the dismissal of over
500 workers and the termination of cooperation with more than 200
domestic companies," SeeNews quotes Mr. Pejovic as saying.

Earlier this month, local media reported KAP is planning to suspend
production operations due to the high energy costs that the company
will incur after the expiry of its power supply contract with
state-controlled power utility Elektroprivreda Crne Gore (EPCG) on
Jan. 1, SeeNews recounts.

According to SeeNews in a separate statement issued on Dec. 8, EPCG
called on Uniprom to return to the negotiations.

"EPCG cannot allow a loss of over EUR60 million to be generated by
supplying electricity at the current price.  In this regard, firmly
committed to protecting the interests of the company, and thus the
interest of the whole country, EPCG wants to preserve its financial
stability with new contracts taking into account the rising
electricity prices in the market," SeeNews quotes the company as
saying.

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




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

E-MAC 2004-II: Fitch Affirms CCC Rating on Class E Tranche
----------------------------------------------------------
Fitch Ratings has upgraded eight tranches of two E-MAC NL RMBS
transactions. The Outlook is Stable.

       DEBT                RATING            PRIOR
       ----                ------            -----
E-MAC NL 2005-I B.V.

Class A XS0216513118   LT A+sf   Upgrade     Asf
Class B XS0216513548   LT A+sf   Upgrade     Asf
Class C XS0216513977   LT A+sf   Upgrade     Asf
Class D XS0216514199   LT A+sf   Upgrade     Asf

E-MAC NL 2004-II B.V.

Class A XS0207208165   LT A+sf   Upgrade     Asf
Class B XS0207209569   LT A+sf   Upgrade     Asf
Class C XS0207210906   LT A+sf   Upgrade     Asf
Class D XS0207211037   LT A+sf   Upgrade     Asf
Class E XS0207264077   LT CCCsf  Affirmed    CCCsf

TRANSACTION SUMMARY

The E-MAC transactions are seasoned true-sale securitisations of
Dutch residential mortgage loans originated by GMAC-RFC Nederland
B.V. CMIS Nederland B.V. is the servicer.


KEY RATING DRIVERS
Counterparty Rating Reviewed: The ratings of eight tranches were
upgraded to 'A+sf' to reflect the current deposit rating of
collection account bank provider, ABN AMRO Bank N.V. These were
previously capped at the IDR of the bank, whereas they should have
been capped at the bank's deposit rating, which was newly assigned
in September 2020. This rating action corrects this error.

The revision of the Outlooks to Stable reflects a recent rating
action on the collection account bank provider ABN AMRO N.V (see
"Fitch Revises ABN AMRO's Outlook to Stable; Affirms at 'A'").

Fitch continues to cap the 2004-II and 2005-I notes' ratings, due
to a lack of replacement language for the collection account bank
in these transactions. The rating cap reflects potential losses for
all notes stemming from commingling losses in combination with
pro-rata payments.

RATING SENSITIVITIES

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

-- A downgrade of the collection account bank may result in a
    corresponding action for both transactions.

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

-- An upgrade of the collection account bank may result in a
    corresponding action for both transactions.

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

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

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

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

ESG CONSIDERATIONS

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

WP/AP TELECOM IV: Moody's Rates New EUR800MM Sr. Secured Notes 'B1'
-------------------------------------------------------------------
Moody's Investors Service has assigned a B1 rating to the proposed
EUR800 million guaranteed senior secured notes due 2028 to be
issued by WP/AP Telecom Holdings IV B.V., and a Caa1 rating to the
proposed EUR550 million guaranteed senior unsecured notes due 2029
to be issued by WP/AP Telecom Holdings III B.V. (T-Mobile NL), the
ultimate holding company for Dutch mobile telecommunications
operator T-Mobile Netherlands Holding B.V.

Concurrently, Moody's has assigned a B1 rating to the EUR700
million guaranteed senior secured revolving credit facility ("RCF")
due 2028 issued by WP/AP Telecom Holdings IV B.V.

The outlook on the ratings is stable.

Proceeds from the proposed notes will be used to finance the
takeover offer of T-Mobile NL by a consortium of private equity
funds managed by private equity sponsors Apax Partners and Warburg
Pincus LLC.

RATINGS RATIONALE

T-Mobile NL's corporate family rating ("CFR") takes into account
(1) its leading position in the Dutch B2C mobile telecommunications
market; (2) its high network quality and stronger than peers'
spectrum portfolio; (3) its track record of growth in both the
mobile and fixed-line segment following the successful integration
of Tele 2 Netherlands, the MVNO Simpel and wireless, broadband and
TV provider Vodafone Thuis; and (4) its sustained positive free
cash flow generation and good liquidity.

The rating however also factors in (1) the company's single country
presence and "challenger" position as the #3 telecoms operator in
The Netherlands in terms of market share, with 15%, after
Koninklijke KPN N.V. (KPN, Baa3 stable) with 36% and VodafoneZiggo
Group B.V. (VodafoneZiggo, B1 stable) with 35%; (2) its reliance on
third party networks for the provision of fixed-line services; (3)
its elevated post-LBO leverage measured by Moody's adjusted
debt/EBITDA of 6.4x at closing, and (4) the execution risks
associated with the separation from the DT Group.

T-Mobile NL's probability of default rating ("PDR") of B2-PD is at
the same level as the CFR, reflecting the use of the standard 50%
family recovery rate as is customary for capital structures that
include both term loans and bonds.

The guaranteed senior secured notes and the guaranteed senior
secured RCF are rated B1, one notch above the CFR. This reflects
the structural and contractual seniority of this class of debt
(together with the term loan). The senior secured debt benefits
from guarantees from operating companies as well as a security on
shares, intercompany receivables, and material bank accounts.

The Caa1 rating on the guaranteed senior unsecured notes reflects
its contractual subordination to the senior lender liabilities,
including the EUR2.4 billion guaranteed senior secured term loan B,
the EUR700 million guaranteed senior secured RCF, and the EUR800
million guaranteed senior secured notes.

RATIONALE FOR STABLE OUTLOOK

Given the high initial leverage, the rating is initially weakly
positioned in the B2 category. The stable outlook on the rating
reflects Moody's expectation that T-Mobile NL's strong operating
performance and positive momentum will allow it to progressively
reduce leverage towards 6.0x by 2023.

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

Upward rating pressure is currently limited. However, upward
pressure could develop overtime if the company's operating
performance remains strong allowing the company (1) to reduce its
Moody's adjusted gross debt-to-EBITDA ratio below 5.25x, (2)
improve its RCF/ debt ratio above 15% and (3) it maintains positive
and growing free cash flow generation.

Conversely, downward pressure on the rating could materialise if
the company fails to deliver on its business plan so that its
leverage measured by Moody's adjusted gross debt/EBITDA remains
above 6x for more than 24 months, RCF/ debt falls below 10% or its
free cash flow generation turns negative on a sustained basis. A
weakening in the company's market positioning and liquidity profile
could also have a negative effect on the ratings.

LIST OF AFFECTED RATINGS

Assignments:

Issuer: WP/AP Telecom Holdings III B.V.

BACKED Senior Unsecured Regular Bond/Debenture, Assigned Caa1

Issuer: WP/AP Telecom Holdings IV B.V.

BACKED Senior Secured Bank Credit Facility, Assigned B1

BACKED Senior Secured Regular Bond/Debenture, Assigned B1

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was
Telecommunications Service Providers published in January 2017.

COMPANY PROFILE

T-Mobile NL, headquartered in The Hague, Netherlands, is the
country's third-largest telecommunications company providing
mobile, fixed-line and broadband services to residential and
business customers. As of December 2020, T-Mobile NL had 42%
consumer mobile market share in the Netherlands (based on the
number of active SIMs) and served almost 700,000 broadband
customers. In 2020, T-Mobile NL reported EUR1.9 billion of revenues
and EUR707 million of EBITDA.



===========
P O L A N D
===========

ALIOR BANK: Fitch Affirms 'BB' LT IDR, Alters Outlook to Stable
---------------------------------------------------------------
Fitch Ratings has revised Alior Bank S.A.'s (Alior) Outlook to
Stable from Negative, while affirming the bank's Long-Term Issuer
Default Rating (IDR) at 'BB' and Viability Rating at 'bb'.

The revision of the Outlook reflects the bank's
better-than-anticipated financial performance during the pandemic
and Poland's sound economic prospects. Fitch believes that downside
risks to Alior's profitability and asset quality have largely
receded, reducing pressure on the bank's capitalisation. Moreover,
Fitch expects Alior to generate sufficient pre-impairment profit to
accommodate its planned growth and compensate the transitional
effect on capital from the phase-in adjustments of IFRS9 first-time
application and pandemic-driven Capital Requirement Regulations
(CRR) 'quick-fix'.

Fitch has withdrawn Alior's Support Rating of '5' and Support
Rating Floor of 'No Floor' as they are no longer relevant to the
agency's coverage following the publication of its updated Bank
Rating Criteria on 12 November 2021. In line with the updated
criteria, Fitch has assigned Alior a Government Support Rating
(GSR) of 'No Support'.

KEY RATING DRIVERS

IDRs, VR and NATIONAL RATINGS

Alior's ratings reflect a moderately seasoned business model that
is prone to the adverse changes in the business and economic
conditions and only a moderate overall franchise. Alior is a
medium-sized bank in the competitive Polish sector with around a 4%
market share of assets resulting in limited pricing power. Its
business model, although gradually evolving, is still characterised
by a higher risk appetite than higher rated peers', due to the
bank's focus on unsecured consumer lending and micro/SME segments.
These factors drive Fitch's assessment of the bank's business
profile at 'bb', which is below the implied 'bbb' score.

The ratings also consider Alior's moderate capitalisation relative
to the bank's risk profile, and weak, although improving, asset
quality. At the same time, the ratings are supported by healthy
funding and tightened risk controls and underwriting standards.

Business transformation at Alior has progressed beyond Fitch's
initial expectations in the reduction of legacy problem loans,
changes in its lending mix, optimisation of operating and funding
costs and profitability recovery. However, frequent changes to top
management result in heightened execution risk and may affect the
bank's business profile. Consequently, Fitch has assigned a '4' ESG
relevance score for management strategy.

The bank's asset quality continues to be a rating weakness, due to
above-sector-average Stage 3 loans ratio (12.5% at end-3Q21;
sector: about 6%), larger credit losses than peers' and material
concentration in higher-risk exposures, such as unsecured retail
loans (36% of loans at end-3Q21). Nonetheless, Fitch expects the
bank's asset quality to gradually improve, supported by loan-book
clean-up through non-performing loan (NPL) sales and write-offs and
improved economic prospects in Poland. New loans are of better
quality and focused on less capital-absorbing exposures (mortgages
and leasing).

Alior benefits from one of the highest but narrowing net interest
margin in the sector (9M21: 3.7%, sector average: about 2%) and
reasonable cost efficiency (cost/income based on Fitch's definition
at 52%). Nevertheless, this is counterbalanced by structurally
higher loan impairment charges (LICs), which on average accounted
for more than 2% of gross loans in the last four years. Alior's
operating profitability returned to a positive 1.6% of
risk-weighted assets (RWAs) in 9M21 (-0.2% in 2020), as the bank
benefited from lower LICs relative to 2020. Fitch expects margins
to gradually recover in 2022, supported by higher market interest
rates and loan growth, while LICs will remain close to 9M21 levels,
due to continued clean-up of its legacy portfolio.

Capitalisation is moderate relative to the risks the bank faces,
with common equity Tier 1 (CET1) and total capital ratios equal to
13.5% and 15.3%, respectively, at end-3Q21. Therefore, Fitch scores
this factor at 'bb', which is below the implied level of 'bbb'. Net
impaired loans represented a still high 36% of CET1 capital. In
Fitch's view, Alior's capitalisation will remain adequate in the
next two years, supported by the sound profitability prospects, and
sufficient to accommodate planned asset growth and amortisation of
IFRS9 and CRR Quick-Fix transitional effect. As a backup, the bank
holds undrawn credit-risk guarantee from its minority, but
controlling, shareholder Powszechny Zaklad Ubezpieczen (PZU). If
fully utilised, it could increase the bank's CET1 ratio by up to
about 60bp.

Alior is self-funded with generally stable and granular customer
deposits that represented 94% of total liabilities at end-3Q21. Its
healthy funding profile is reflected in a stable gross
loans/deposits ratio close to 100%. Liquidity is well-managed and
supported by a reasonable buffer of high-quality liquid assets that
represented around 18% of assets. The bank's liquidity coverage
ratio was sound at 156% at end-3Q21.

Alior's Short-Term IDR of 'B' is in line with the 'BB' Long-Term
IDR under Fitch's rating correspondence table. The National Ratings
reflect the bank's creditworthiness relative to Polish peers'.

GSR

The GSR of 'No Support' for Alior express Fitch's opinion that
potential sovereign support for the bank cannot be relied on. This
is underpinned by the Polish resolution legal framework, which
requires senior creditors to participate in losses, if necessary,
instead or ahead of a bank receiving sovereign support.

RATING SENSITIVITIES

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

-- The bank's VR and Long-Term IDR could be downgraded if asset
    quality weakens, in particular if Stage 3 loans increase on a
    sustained basis or if Fitch expects Alior to be unable to
    maintain reasonable capital buffers. A downgrade could be also
    triggered by significant deterioration of the bank's operating
    profitability without clear prospects for recovery.

-- The National Ratings are sensitive to negative changes to the
    bank's Long-Term IDR and the bank's credit profile relative to
    Polish peers'.

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

-- An upgrade of the bank's VR and Long-Term IDR would require a
    combination of: i) proven record of operations with reduced
    risk appetite, accompanied by a sustained improvement in
    asset-quality metrics; ii) operating profit/RWA stabilizing
    above 1.5% and iii) stronger capital buffers.

-- The National Ratings are sensitive to positive changes to the
    bank's Long-Term IDR and the bank's credit profile relative to
    Polish peers'.

-- Domestic resolution legislation limits the potential for
    positive rating action on the bank's GSR. The Shareholder
    Support Rating could be assigned if Fitch takes the view of at
    least a limited probability of support from PZU that
    effectively controls the bank.

VR ADJUSTMENTS

The business profile score of 'bb' has been assigned below the
'bbb' category implied score for Alior, due to the following
adjustment reasons: business model (negative) and market position
(negative).

The capitalisation and leverage score of 'bb' has been assigned
below the bbb' category implied score, due to the following
adjustment reason: risk profile and business model (negative).

BEST/WORST CASE RATING SCENARIO

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

ESG CONSIDERATIONS

Alior has an ESG Relevance Score of '4' for Management Strategy,
due to heightened execution risk of its business plan given high
management turnover in the bank. This is not a key rating driver
but has a negative impact on the credit profile (especially Fitch's
assessment of business profile) and is relevant to the ratings in
conjunction with other factors.

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



=====================
S W I T Z E R L A N D
=====================

ARCHROMA HOLDINGS: Moody's Hikes CFR to B2, Outlook Remains Stable
------------------------------------------------------------------
Moody's Investors Service upgraded to B2 from B3 the corporate
family rating and upgraded to B2-PD from B3-PD the probability of
default rating of Archroma Holdings Sarl ('Archroma'). Moody's also
affirmed the B2 the guaranteed senior secured first lien Term Loan
B due in 2024, as well as the USD75 million committed guaranteed
senior secured revolving credit facility and the USD 75 million
equivalent guaranteed senior secured term loan facility, both due
in 2023 (RCF and capex facilities). Moody's expects to withdraw the
rating on the Second Lien facility due in 2025 upon its full
repayment in December 2021. The borrower of all these facilities is
Archroma Finance Sarl, a holding company 100% controlled by
Archroma Holdings Sarl. The outlook on both entities remains
stable.

RATINGS RATIONALE

The upgrade of Archroma's CFR to B2 reflects the relatively swift
recovery (15% sales growth in fiscal 2020/21) from the Covid 19
pandemic in 2020 in combination with a successful efficiency
program reducing the company's cost base, as well as gross debt
reduction. Archroma used its ample cash balance of $152 million (as
of fiscal year end of September 21) to voluntarily repay $90million
of its $105 million Second Lien facility in November 2021 and will
repay the remaining $15 million before end of 2021. As a result
Moody's expects Archroma's gross leverage to decline towards 5.5x
gross debt / EBITDA by the fiscal year ending September 2022 from
6.4x at the end of September 21 and to reduce its interest expense
by about $8.5 million.

Archroma's (i) leading position in the textile chemical sector;
(ii) good track record of integrating assets and implementing
efficiency initiatives to enhance operating profitability; (iii)
balanced global geographic presence, with revenues spread across
the Americas, Asia and EMEA; (iv) broad product portfolio
increasingly focused on environmental friendly textile chemicals
systems, and (v) large customer base spread across its three core
business lines of textile chemicals, paper solutions and emulsions
support its B2 rating.

At the same time, the CFR reflects (i) the high exposure of the
company to mature markets, particularly Europe and North America;
(ii) exposure to the relatively volatile textile end market and;
(iii) the fairly aggressive financial policies as evidenced by the
relatively high leverage as a result of a dividend recap in 2017
and some moderate M&A risk as the company aims to further
consolidate the textile market for chemicals.

LIQUIDITY

Moody's consider Archroma's liquidity strong. The company had $152
million cash on balance as of September 2021, or about $47 million
pro forma for the repayment of its $105 million Second Lien
facility, as well as access to its committed and undrawn $75m
million revolving credit facility ('RCF') maturing in August 2023.
Moody's project the company to generate ample funds from operations
of about $60 million - $70 million, which in combination with the
cash on balance will easily cover small expected working capital
outflows and capital expenditure of about $33 million, as well as
limited scheduled debt amortization (less than $3 million per year
under the term loan). The company has no significant maturities
prior to the RCF and term loan in August 2023 and 2024,
respectively.

The credit agreements are covenant-lite, with a single senior net
leverage covenant set at a 6.75x maximum (vs. 4.7x reported at FYE
in September 2021). Moody's expects the RCF to remain largely
undrawn and Archroma to maintain a comfortable buffer under the RCF
covenant during the next 12-18 months.

OUTLOOK

The stable outlook assumes timely refinancing of the revolver
maturity and that the continuous improvements in operating
performance in combination with the repayment of the Second Lien
term loan will facilitate credit metrics in line with the
expectations for the B2 rating.

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

An upgrade of Archroma's ratings could be considered if pressure on
end markets would cease enabling the company to: (i) reduce it
adjusted debt to EBITDA well below 5.0x on a sustained basis; (ii)
increase adj EBITDA margins towards mid double digits; (iii)
generate sustained positive free cash flows as evidenced by adj.
FCF/debt increasing sustainably into high single digits; and (iii)
maintain good liquidity. A higher rating would also require a
public commitment to a financial policy in line with expectations
for a B1 rating.

Moody's would consider downgrading the rating if the company were
to perform materially below expectations, as evidenced by: (i)
operational performance materially below Moody's expectations (ii)
adjusted debt/EBITDA increasing above 6.0x on a sustained basis;
(iii) meaningful negative free cash flow or additional debt draw
downs, which would result in a weakening of the group's liquidity,
including through weak cushion relative to maintenance covenants;
or (iv) lack of progress on timely refinancing of the capital
structure ahead of its RCF coming due in August 2023.

ESG

Governance considerations, including the repayment of the second
lien term lien term loan and the upcoming debt maturities, have
been a driver of the rating action.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Chemical
Industry published in March 2019.

COMPANY PROFILE

Swiss-based Archroma is a global leader in the textile chemicals
(64% of its revenues in fiscal 2020/21), paper solutions and
emulsion products businesses. In FY ending September 2021, Archroma
reported consolidated revenues of USD1,287m and an adjusted EBITDA
margin of 12.1%.



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

ISTANBUL METROPOLITAN: Moody's Affirms B2 Long Term Issuer Rating
-----------------------------------------------------------------
Moody's Investors Service has affirmed the B2 long-term issuer and
senior unsecured debt ratings of the Metropolitan Municipality of
Istanbul and the B2 long-term issuer ratings assigned to the
Metropolitan Municipality of Izmir. At the same time, Moody's has
downgraded the National Scale long-term issuer rating of Izmir to
A1.tr from Aa3.tr. The outlooks on both municipalities remain
negative.

The rating action follows the affirmation of the Turkish
government's B2 bond rating with negative outlook.

RATINGS RATIONALE

RATIONALE FOR THE RATING AFFIRMATIONS

The rating action reflects the cities' record of persistently
strong operating performance, which is continuing despite the
pandemic crisis thanks to strong tax revenue dynamics fueled by
growing economies, high tax generation capacity and flexibility to
withstand adverse development. It also takes into account the
cities' huge investment needs over the next years to sustain rapid
urbanization.

Both cities displayed strong gross operating balances (GOB) in
2020, with the City of Istanbul posting an improved GOB of 33% of
operating revenue from 28% a year before, while Izmir's GOB
remained overall stable at 43% of operating revenue. In 2021,
Moody's expects strong increases in tax revenues benefitting from
this year's extraordinary real GDP growth rate of 9%.
Inflation-adjusted operating expenditures growth has remained under
control (except interest costs), despite increased responsibilities
due to the coronavirus pandemic, which will continue to put
pressure on cities' finances. As a result, Moody's expects the City
of Istanbul to maintain its strong GOB at around 30% of operating
revenue, while Izmir will post a stronger operating performance,
with GOB at 45% of operating revenue.

These levels of operating balances provide a good funding source
for Istanbul and Izmir's traditionally very high capital
expenditures. However, the cities' huge investment needs driven by
the fast population growth and rapid urbanization translate into
growing pressure on their finances, resulting in financing
deficit-to-total revenue ratio of 9.4% for Istanbul and 21.5% for
Izmir in 2020, a trend which is expected to continue in 2021 and
2022.

The rating affirmation also takes into account Istanbul and Izmir's
robust and diversified economic bases contributing 30% and 8% to
the national GDP, respectively, with wealth levels well above the
national average that enable them to rely on a relatively stable
tax revenue base and remain resilient to adverse economic shocks.
In addition, both cities have large asset bases, which could help
mitigate potential pressure on their finances in the medium term in
case of need.

Istanbul and Izmir are rated on par with the Turkish government
bond rating of B2 negative. Due to their close institutional,
financial and operational linkages with the Turkish government,
Istanbul and Izmir cannot act independently of the sovereign and do
not have enough financial flexibility to permit their credit
quality to be stronger than that of the sovereign. In Moody's view,
the current operating environment, which is marked by high
inflation and currency volatility, constrain the predictability and
stability of Istanbul and Izmir's revenue raising powers and
service responsibilities.

The B2 ratings incorporate a Baseline Credit Assessment (BCA) of b2
assigned to the cities of Istanbul and Izmir.

RATIONALE FOR MAINTAINING THE NEGATIVE OUTLOOKS

The negative outlook on both cities reflects their high and growing
debt with high FX exposures.

Istanbul and Izmir will further increase their debt levels during
2021-22, ranging from 100% to 110% of operating revenue,
respectively. Both cities display very high exposure to FX, with
Istanbul and Izmir having respectively around 80% and 75% of their
direct debt stock denominated in foreign currency. The growing
fiscal pressure stemming from Turkish lira depreciation - by nearly
30% since the central bank started to ease monetary policy in
September - has an impact on the cities' debt increase and growing
debt servicing costs, which reduces their debt affordability.

The negative outlook also mirrors the outlook of the Government of
Turkey.

ENVIRONMENTAL, SOCIAL, GOVERNANCE CONSIDERATIONS

Environmental considerations are material to Istanbul and Izmir's
ratings. Istanbul and Izmir's main risks relates to high level of
carbon intensity and greenhouse gas emissions within their
economies.

Social considerations are material to Istanbul and Izmir's ratings.
Both cities have a favourable demographic profile, but with the
fast-growing population and recent expansion of the cities'
boundaries, the overall provision of services to the population
falls short of the standards in most OECD countries.

Governance risks are material to Istanbul and Izmir's ratings.
Istanbul and Izmir have shown an ability to manage complex projects
in the rapidly growing cities and provide services within the
metropolitan areas with a population of 15 million and 4.5 million,
respectively. Their debt management has an impact on cities'
profile, mainly due to exposure to foreign currency risk.

The specific economic indicators, as required by EU regulation, are
not available for these entities. The following national economic
indicators are relevant to the sovereign rating, which was used as
an input to this credit rating action.

Sovereign Issuer: Turkey, Government of

GDP per capita (PPP basis, US$): 30,449 (2020 Actual) (also known
as Per Capita Income)

Real GDP growth (% change): 1.8% (2020 Actual) (also known as GDP
Growth)

Inflation Rate (CPI, % change Dec/Dec): 14.6% (2020 Actual)

Gen. Gov. Financial Balance/GDP: -4.2% (2020 Actual) (also known as
Fiscal Balance)

Current Account Balance/GDP: -4.9% (2020 Actual) (also known as
External Balance)

External debt/GDP: [not available]

Economic resiliency: ba2

Default history: At least one default event (on bonds and/or loans)
has been recorded since 1983.

SUMMARY OF MINUTES FROM RATING COMMITTEE

On December 02, 2021, a rating committee was called to discuss the
rating of the Istanbul, Metropolitan Municipality of; Izmir,
Metropolitan Municipality of. The main points raised during the
discussion were: The issuer's governance and/or management, have
not materially changed. The issuer's fiscal or financial strength,
including its debt profile, has not materially changed. The
systemic risk in which the issuer operates has not materially
changed.

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

An upgrade of the cities' ratings will require a similar change in
Turkey's sovereign rating provided that the cities show improving
financial and debt metrics.

A deterioration of the sovereign credit strength would apply
downward pressure on Istanbul and Izmir's ratings given the close
financial and operational linkages with the central government.

Downward ratings pressure may arise from a sustained growth in debt
and debt servicing costs, triggered by further currency
depreciation and the knock-on effect from outstanding FX-debt. Any
concern in access to funding sources would also trigger a negative
rating action.

The principal methodology used in these ratings was Regional and
Local Governments published in January 2018.

ULKER BISKUVI: Fitch Lowers LT FC IDR to 'B+', Outlook Negative
---------------------------------------------------------------
Fitch Ratings has downgraded Ulker Biskuvi Sanayi A.S.'s Long-Term
Foreign-Currency Issuer Default Rating (IDR) to 'B+' from 'BB-'.
The Outlook is Negative. Fitch has also downgraded the senior
unsecured rating to 'B+'/RR4 from 'BB-'/RR4.

The downgrade reflects Fitch's expectation that Ulker's leverage
will stay elevated over 2022-2023 after rising in 2021, driven by
significant Turkish lira depreciation relative to hard currencies,
in which the company funds itself. In addition, a weak local
currency will amplify pressure on the EBITDA margin from increased
input costs, which are mostly denominated in hard currencies.

The rating is supported by Ulker's strong market position in the
Turkish confectionery market and Fitch's expectation of generally
positive, albeit volatile, free cash flow (FCF) generation
(post-dividends). Fitch also assumes that Ulker will be able to
gradually pass cost increases through to consumers and restore its
EBITDA margin after the temporary reduction in 2021-2022.

The Negative Outlook incorporates increased refinancing risks with
regard to large debt maturities in 2023 and uncertainty around
Ulker's deleveraging path and cash-management policy in terms of
allocations to financial investments (which Fitch does not treat as
readily-available cash).

KEY RATING DRIVERS

Sizeable Hard-Currency Debt: Ulker's leverage metrics are
vulnerable to the recent sharp depreciation of the Turkish lira as
it has large debt that is almost fully denominated in hard currency
(99% of total at end-September 2021). Ulker's foreign operations
and its policy to maintain around 80% of cash in hard currency help
reduce FX exposure but do not fully eliminate FX risks. In 2020,
foreign operations accounted for 40% of Ulker's revenue and 50% of
EBITDA. This is beneficial for the risk profile due to hard
currency-denominated exports and sales in Saudi riyal and United
Arab Emirates dirham, which are pegged to the US dollar.

Step-Up in Leverage: Fitch expects the recent sharp lira
devaluation to drive a significant increase in Ulker's FFO net
leverage to over 7.0x in 2021 (2020: 5.2x), derailing previously
projected deleveraging. Ulker consolidated more debt with the
acquisition of Onem Gıda Sanayi ve Ticaret A.S. in 3Q21 than Fitch
previously anticipated, which also contributed to increasing
leverage, albeit to a lesser extent. Fitch expects leverage to
reduce from this excessive level, but in Fitch's rating case FFO
net leverage remains above 5x over 2021-2023. Fitch considers this
is still high for Ulker's 'B+' rating. The uncertainty around
leverage reduction to below 5x is reflected in the Negative
Outlook.

Financial Investments Excluded: Fitch does not treat reported
financial investments (TRY4.3 billion at end-September 2021) as a
reliable liquidity source and therefore does not take them into
account for net leverage calculations and FX exposure calculations
unlike Ulker. Such instruments consist of hard-currency investments
in traded equity, fixed income and alternative investments, which
may be subject to market fluctuations. Fitch assumes that these
investments are likely to be liquidated for debt repayment only if
refinancing options are not available. In a more stable
environment, Fitch assumes they could be used to fund potential
M&A.

Opportunistic Cash Management: The rating considers the uncertainty
around Ulker's cash management decisions as there is no policy on
how much cash can be allocated to investments in financial assets
and loans to related parties. Fitch's negative rating sensitivity
was breached in 2020 as the company's cash balance was reduced due
to the loan Ulker provided to Yildiz and the allocation of part of
the cash to investments in financial assets. The loan was supposed
to be returned to Ulker to fund the recent acquisition of Onem but
part of it remained outstanding at end-September 2021 (TRY565
million out of TRY2.2 billion at end-2020).

EBITDA Margin Under Pressure: Fitch projects Ulker's EBITDA margin
will have reduced in 2021 for the first time in a decade, due to
unprecedented price inflation in raw materials and packaging, which
is challenging food producers globally. The pressure on Ulker's
margin is amplified by the weakness of the Turkish lira against
hard currencies, in which the confectioner's major inputs are
denominated. Fitch expects EBITDA margin will reduce further in
2022 as hedging under favourable prices expires but will start
recovering from 2023.

Positive FCF: The ratings are supported by Ulker's ability to
generate FCF, which Fitch expects to be sustained over 2021-2024 as
the company has completed its investment cycle and now has low
capex needs. This is despite a resumption of dividend payments from
2021 after having paid no dividends in 2019 and 2020. However,
Fitch expects some volatility in FCF, partly due to large working
capital swings driven by inflation.

Ring-Fenced from Parent: The rating is premised on Ulker remaining
ring-fenced from the rest of Yildiz group and Fitch assumes that
Ulker's cash flows will not be used to service the substantial debt
of Yildiz or Ulker's sister companies. However, Fitch includes in
Fitch's calculation of leverage metrics the guarantees Ulker
provides for obligations of third parties. Off-balance sheet
obligations reduced materially after Onem's acquisition as the
guarantee Ulker provides for Onem's obligations is now within the
consolidation scope.

Group Structure Complexities: Ulker has an ESG Relevance Score of
'4' for Group Structure as its operations are characterised by
connections with companies that are ultimately owned by its
shareholder, Yildiz. These related-party transactions are mostly in
the company's ordinary business, including sales to modern and
traditional retail and procurement of chocolate dough and flour
from Onem. Financial transparency improved after Ulker acquired
Onem as purchases from Onem accounted for 35% of Ulker's costs of
goods sold in 2020.

Additionally, Ulker pays royalties to Yildiz, the owner of the
brands under which Ulker markets its products. Fitch assumes these
transactions will continue to be conducted at arm's length and will
not result in significant cash leakage outside Ulker's consolidated
scope of activities.

DERIVATION SUMMARY

Ulker compares well against Argentinean confectionery producer
Arcor S.A.I.C. (Foreign-Currency IDR: B/Stable, Local-Currency IDR:
B+/Stable) due to similar operational scale, strength of local
brands and geographic diversification. Both companies generate
about 30%-40% of revenue outside their domestic markets. Ulker's
rating is the same as Arcor's Local-Currency IDR, despite stronger
EBITDA margins, positive FCF and lower volatility in operating
performance. This is because these strengths are offset by
significantly higher leverage. Arcor's Foreign-Currency IDR cannot
be rated more than one notch higher than Argentina's Country
Ceiling.

Ulker is also rated higher than Russia's largest confectionery
producer JSC Holding Company United Confectioners (B/Stable) as it
benefits from larger market shares in its domestic market, better
geographic diversification and the resulting larger business scale.
United Confectioners has weaker financial transparency and opaque
related-party transactions, which constrain its rating, despite its
more conservative leverage.

Ulker is rated lower than Mexico-based Grupo Bimbo, S.A.B. de C.V.
(BBB/Stable), the world's largest baked goods producer with about a
3% market share, due to its smaller scale and geographic footprint
and higher leverage.

No parent-subsidiary linkage, Country Ceiling or operating
environment aspects were applied to Ulker's rating. Fitch could
consider linking Ulker's rating to Yildiz's credit profile if the
current ringfencing weakens.

KEY ASSUMPTIONS

-- USD/TRY at 12.7 at end-2021, 14.0 at end-2022 and 15.0 at end-
    2023;

-- Revenue CAGR of 22% over 2021-2024, driven mostly by inflation
    in 2021-2022;

-- EBITDA margin reducing in 2021 and 2022 before recovering
    gradually over 2023-2024;

-- No investment in financial assets in 2022;

-- Capex at TRY250 million-TRY300 million a year to 2024;

-- Dividends of TRY350 million a year.

KEY RECOVERY RATING ASSUMPTIONS

Under Corporates Recovery Ratings and Instrument Ratings Criteria,
Fitch applies bespoke approach to recovery analysis for issuers
rated 'B+' and below. This analysis is performed for Ulker for the
first time. Fitch's recovery analysis assumes that Ulker would be
reorganized as a going-concern in bankruptcy rather than
liquidated, given the inherent value in its brands and market
positions. Fitch has assumed a 10% administrative claim.

Fitch assesses Ulker's going-concern (GC) EBITDA at around USD185
million. Fitch estimates that at this level of EBITDA, after the
undertaking of corrective measures, the company would generate
neutral to negative FCF. An EV multiple of 4.5x EBITDA is applied
to the GC EBITDA to calculate a post-reorganization enterprise
value, reflecting a slight discount compared to Ulker's current
EV/EBITDA multiple of around 5.7x. It is also slightly higher than
4x that Fitch assumes for Ukrainian poultry producer MHP SE (B+/
Stable).

In Fitch's debt waterfall Fitch assumes that Ulker's debt ranks
pari-passu as it is unsecured and raised by operating companies.
Ulker Biskuvi Sanayi A.S., which bears around 80% of the group's
debt, is the second largest operating company within the group.

Fitch's waterfall analysis generated a ranked recovery for the
senior unsecured debt, including its USD650 million Eurobond, in
the 'RR3' band, indicating a higher rating than the IDR as the
waterfall analysis output percentage on current metrics and
assumptions was 52%. However, the Eurobond is rated in line with
Ulker's IDR of 'B+' as notching up is not possible due to the
Turkish jurisdiction. The Recovery Rating and the waterfall
analysis output percentage are capped at 'RR4' and 50%
respectively.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/revision of the Outlook to Stable:

-- Visibility on FFO net leverage reducing below 5.0x on a
    sustained basis;

-- Progress with refinancing debt maturing in 2023.

While Fitch does not envisage currently a rating upgrade to 'BB-',
factors that could lead to an upgrade include:

-- FFO net leverage consistently below 4x supported by a
    consistent financial and cash management policy;

-- Stable market share in Turkey or internationally;

-- Positive FCF on a sustained basis.

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

-- FFO net leverage consistently above 5.0x;

-- Larger-than-assumed M&A, investments in high-risk securities
    or related-party transactions leading to significant cash
    leakage outside Ulker's scope of consolidation;

-- Increased competition eroding Ulker's market share in Turkey
    or internationally;

-- Deterioration in FCF profile on a sustained basis.

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

Adequate Liquidity: Fitch estimates that under USD/TRY at 12.7, at
end-September 2021, Ulker had cash and cash equivalents of TRY3.6
billion, which together with expected positive FCF, was sufficient
to cover TRY3.2 billion of short-term debt.

Ulker's next material debt maturity is in April 2023, when its
USD110 million and EUR244 million syndicated loan and EUR75 million
EBRD loan are due. Fitch believes refinancing risks increased due
to sharp lira devaluation and deteriorated economic environment in
Turkey. This is reflected in Negative Outlook on the rating.
However, risks would reduce if Ulker liquidates a part of its
sizeable financial assets portfolio, which Fitch believes could
happen in case refinancing is unavailable.

ISSUER PROFILE

Ulker is the largest confectionary producer in Turkey
(BB-/Negative), with presence in Saudi Arabia, Egypt, Kazakhstan,
UAE and exporting mainly to the rest of MENA countries but also to
USA, UK, China or Japan.

ESG CONSIDERATIONS

Ulker has an ESG Relevance Score of '4' for Group Structure due to
the complexity of the structure of the wider Yildiz group and
material related-party transactions. This ESG score currently has a
negative impact on the credit profile, and is relevant to the
rating in conjunction with other factors.

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



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

ALHAMBRA: Goes Into Receivership, Building Up for Sale
------------------------------------------------------
David Walsh at The Star reports that The Alhambra shopping centre
in Barnsley town centre has gone bust.

According to The Star, receivers have been appointed to sell the
building, which has 40 shop units and operators including Wilko,
Primark and Iceland.

Receiver Andrew Foster said his appointment would have "no
operational impact on the tenants or shoppers, and the centre will
continue to trade as normal", The Star relates.

The centre opened in 1991.  The freehold is held by Barnsley
Council and it is leased by Barnsley Shopping Centre Ltd.



NATIONAL BANK: Fitch Affirms Then Withdraws 'B+' LT IDR
-------------------------------------------------------
Fitch Ratings has affirmed National Bank of Egypt (UK) Limited's
(NBEUK) Long-Term Issuer Default Rating (IDR) at 'B+' with a Stable
Outlook.

Fitch has simultaneously withdrawn NBEUK's ratings for commercial
reasons and will no longer provide ratings and analytical coverage
for NBEUK.

KEY RATING DRIVERS

NBEUK's IDRs are driven by the likelihood of support from parent,
National Bank of Egypt (S.A.E.) (NBE; B+/Stable).

NBEUK's Long -Term IDR of 'B+' is equalised with that of NBE as
Fitch believes that the parent has a high propensity to provide
extraordinary support to its subsidiary, if required. This reflects
its full ownership, significant integration of management,
operations and balance sheet, in addition to the material
reputational damage that a default of NBEUK would cause for NBE. It
also reflects, to a lesser extent, the role that NBEUK plays in the
group as an international window for NBE and Egyptian state
entities. The Stable Outlook on NBEUK's Long-Term IDR reflects that
on NBE.

NBEUK's businesses, including trade-finance activities with
Egyptian counterparties and servicing the UK's Egyptian community,
are inherently dependent on NBE's franchise. In addition, most of
NBEUK's funding is provided either by NBE, Egyptian government
agencies or Egyptian banks. Hence, Fitch has not assigned a
Viability Rating to NBEUK.

RATING SENSITIVITIES

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

NA

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

NA

BEST/WORST CASE RATING SCENARIO

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

ESG CONSIDERATIONS

NBEUK has an ESG Relevance Score of '4' for Governance Structure in
line with NBE's. This reflects Fitch's view that NBE's role in
supporting macroeconomic policies (especially related to
foreign-exchange stability) can have a negative impact on NBEUK's
funding and liquidity profile as demonstrated during 2020. This
reflects NBEUK's high dependence on funding from Egyptian
government entities and NBE. This has a negative impact on the
credit profile and is relevant to the rating in conjunction with
other factors.

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

Following the rating withdrawal Fitch will no longer provide ESG
Relevance Scores for NBEUK.



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

[*] BOOK REVIEW: Hospitals, Health and People
---------------------------------------------
Author: Albert W. Snoke, M.D.
Publisher: Beard Books
Softcover: 232 pages
List Price: $34.95
Order your personal copy today at
http://www.beardbooks.com/beardbooks/hospitals_health_and_people.html

Hospitals, Health and People is an interesting and very readable
account of the career of a hospital administrator and physician
from the 1930's through the 1980's, the formative years of today's
health care system. Although much has changed in hospital
administration and health care since the book was first published
in 1987, Dr. Snoke's discussion of the evolution of the modern
hospital provides a unique and very valuable perspective for
readers who wish to better understand the forces at work in our
current health care system.

The first half of Hospitals, Health and People is devoted to the
functional parts of the hospital system, as observed by Dr. Snoke
between the late 1930's through 1969, when he served first as
assistant director of the Strong Memorial Hospital in Rochester,
New York, and then as the director of the Grace-New Haven Hospital
in Connecticut. In these first chapters, Dr. Snoke examines the
evolution and institutionalization of a number of aspects of the
hospital system, including the financial and community
responsibilities of the hospital administrator, education and
training in hospital administration, the role of the governing
board of a hospital, the dynamics between the hospital
administrator and the medical staff, and the unique role of the
teaching hospital.

The importance of Hospitals, Health and People for today's readers
is due in large part to the author's pivotal role in creating the
modern-day hospital. Dr. Snoke and others in similar positions
played a large part in advocating or forcing change in our hospital
system, particularly in recognizing the importance of the nursing
profession and the contributions of non-physician professionals,
such as psychologists, hearing and speech specialists, and social
workers, to the overall care of the patient. Throughout the first
chapters, there are also many observations on the factors that are
contributing to today's cost of care. Malpractice is just one
example. According to Dr. Snoke, "malpractice premiums were
negligible in the 1950's and 1960's. In 1970, Yale-New Haven's
annual malpractice premiums had mounted to about $150,000." By the
time of the first publication of the book, the hospital's premiums
were costing about $10 million a year.

In the second half of Hospitals, Health and People, Dr. Snoke
addresses the national health care system as we've come to know it,
including insurance and cost containment; the role of the
government in health care; health care for the elderly; home health
care; and the changing role of ethics in health care. It is
particularly interesting to note the role that Senator Wilbur Mills
from Arkansas played in the allocation of costs of hospital-based
specialty components under Part B rather than Part A of the
Medicare bill. Dr. Snoke comments: "This was considered a great
victory by the hospital-based specialists. I was disappointed
because I knew it would cause confusion in working relationships
between hospitals and specialists and among patients covered by
Medicare. I was also concerned about potential cost increases. My
fears were realized. Not only have health costs increased in
certain areas more than anticipated, but confusion is rampant among
the elderly patients and their families, as well as in hospital
business offices and among physicians' secretaries." This aspect of
Medicare caused such confusion that Congress amended Medicare in
1967 to provide that the professional components of radiological
and pathological in-hospital services be reimbursed as if they were
hospital services under Part A rather than part of the co-payment
provisions of Part B.

At the start of his book, Dr. Snoke refers to a small statue,
Discharged Cured, which was given to him in the late 1940's by a
fellow physician, Dr. Jack Masur. Dr. Snoke explains the
significance the statue held for him throughout his professional
career by quoting from an article by Dr. Masur: "The whole question
of the responsibility of the physician, of the hospital, of the
health agency, brings vividly to mind a small statue which I saw a
great many years ago.it is a pathetic little figure of a man, coat
collar turned up and shoulders hunched against the chill winds,
clutching his belongings in a paper bag-shaking, tremulous,
discouraged. He's clearly unfit for work-no employer would dare to
take a chance on hiring him. You know that he will need much more
help before he can face the world with shoulders back and
confidence in himself. The statuette epitomizes the task of medical
rehabilitation: to bridge the gap between the sick and a job."

It is clear that Dr. Snoke devoted his life to exactly that
purpose. Although there is much to criticize in our current
healthcare system, the wellness concept that we expect and accept
today as part of our medical care was almost nonexistent when Dr.
Snoke began his career in the 1930's. Throughout his 50 years in
hospital administration, Dr. Snoke frequently had to focus on the
big picture and the bottom line. He never forgot the importance of
Discharged Cured, however, and his book provides us with a great
appreciation of how compassionate administrators such as Dr. Snoke
have contributed to the state of patient care today. Albert Waldo
Snoke was director of the Grace-New Haven Hospital in New Haven,
Connecticut from 1946 until 1969. In New Haven, Dr. Snoke also
taught hospital administration at Yale University and oversaw the
development of the Yale-New Haven Hospital, serving as its
executive director from 1965-1968. From 1969-1973, Dr. Snoke worked
in Illinois as coordinator of health services in the Office of the
Governor and later as acting executive director of the Illinois
Comprehensive State Health Planning Agency. Dr. Snoke died in April
1988.



                           *********


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

Troubled Company Reporter-Europe is a daily newsletter co-
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Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

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

This material is copyrighted and any commercial use, resale or
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