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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, April 8, 2022, Vol. 23, No. 65

                           Headlines



F R A N C E

RENAULT SA: Moody's Affirms 'Ba2' CFR, Outlook Remains Negative


I R E L A N D

AURIUM CLO IX: S&P Assigns B- (sf) Rating to Class F Notes
AVOCA CLO XXVI: Fitch Gives Final 'B-' Rating to Class F Tranche
AVOCA CLO XXVI: Moody's Assigns B3 Rating to EUR11MM Class F Notes
HARVEST CLO XV: Moody's Affirms B1 Rating on EUR13.5MM F-R Notes
MULCAIR SECURITIES NO. 3: S&P Assigns Prelim B+ Rating to F Notes

PENTA CLO 4: Moody's Affirms B2 Rating on EUR10.45MM Class F Notes
ST. PAUL'S CLO IV: Moody's Affirms B2 Rating on EUR14.3MM E Notes


I T A L Y

POPOLARE BARI 2017: Moody's Cuts EUR80.9MM Cl. A Notes Rating to B2


N E T H E R L A N D S

DOMI 2022-1: S&P Assigns Prelim B- (sf) Rating on Class X Notes
DOMI BV 2022-1: Moody's Assigns (P)Caa2 Rating to EUR10MM X Notes
PEER HOLDING: S&P Raises LT ICR to 'BB-', Outlook Stable


R O M A N I A

ALPHA BANK: Moody's Ups LT Deposit Ratings to Ba1, Outlook Stable


R U S S I A

[*] RUSSIA: Makes Debt Payment in Rubles, Default Likely


S E R B I A

HIP AZOTARA: Commences Trial Production Following Acquisition


S W E D E N

UNIQUE BIDCO: Moody's Assigns First Time 'B2' Corp. Family Rating


U N I T E D   K I N G D O M

AMIGO PLC: Creditors Can Vote on Two Schemes of Arrangement
ARDONAGH MIDCO 2: Fitch Affirms 'B-' LT IDR, Alters Outlook to Pos.
DERBY COUNTY FOOTBALL: Chris Kirchner Named Preferred Bidder
ELVIS UK: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable
LERNEN BONDCO: S&P Affirms 'CCC+' Long-Term Issuer Credit Rating

MECHANICAL FACILITIES: Cash Flow Pressures Prompt Administration
NMCN: Former Employees Files Legal Action Over Redundancy Process
TM LEWIN: Strikes Acquisition Deal with PETRA Group
WARRENS BAKERY: Calls CVA a Success After Return to Profitability


X X X X X X X X

[*] BOOK REVIEW: Hospitals, Health and People

                           - - - - -


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

RENAULT SA: Moody's Affirms 'Ba2' CFR, Outlook Remains Negative
---------------------------------------------------------------
Moody's Investors Service has affirmed Renault S.A.'s (Renault or
group) corporate family rating of Ba2, the probability of default
rating of Ba2-PD, the rating of the group's senior unsecured EMTN
programme of (P)Ba2 and the ratings of the group's senior unsecured
notes of Ba2. The outlook remains negative.

"The affirmation of Renault's ratings reflects the return of
Renault's margins to slightly positive levels since 2021, expected
further improvements, in line with the company's strategic plan
through 2025 and the group's good liquidity.", said Matthias Heck,
a Moody's Vice President -- Senior Credit Officer and Lead Analyst
for Renault. "The negative outlook reflects the weak positioning of
Renault in the Ba2 rating category on the back of still slim
margins, the time-consuming execution period until the strategic
plan results in material improvements in financial metrics and the
suspension of the company's operations in Russia. The rating hence
remains vulnerable to any negative macroeconomic developments.",
added Mr. Heck.

RATINGS RATIONALE

Renault Ba2 CFR reflects its position as one of Europe's largest
car manufacturers, with a solid competitive position in France and
good geographical diversity; the recent new model launches, with an
advanced positioning in the area of hybrid and battery electric
models; the new strategic plan called "Renaulution", which aims to
improve profitability and cash generation with first signs of
success; and its prudent financial policy, good liquidity and
balanced debt maturity profile. The rating also reflects Renault's
ownership of RCI Banque, whose dividend payments contribute to
Renault's industrial cash flows and finally its ability to delever,
and the 15% ownership of French government, which supported Renault
with a EUR4 billion state guaranteed loan during the pandemic.
Lastly, its long-established strategic alliance with Nissan Motor
Co., Ltd. (Nissan) and Mitsubishi Motors Corporation (Mitsubishi)
has substantial synergy potential although the companies had
material challenges to realize this in the past.

The rating also incorporates Renault's low profitability and its
exposure to the cyclicality of the automotive industry; its high
exposure to Europe (including France), which represented more than
half of the group's unit sales in 2021 and where economic
development will be more materially impacted by the conflict
between Russia and the Ukraine; the still limited integration level
of Renault's alliance with Nissan and Mitsubishi and its dependence
on the contribution to its earnings and cash flow from Nissan's
dividends, which has weakened considerably since 2019; and the
ongoing high need for investment spending (capex and R&D) into
alternative fuel and autonomous driving technology, which will
constrain future free cash flow (FCF). Moody's take into
consideration the high management turnover in the recent years, a
negative from a governance perspective.

On March 23, 2022, Renault announced the suspension of its
industrial activities in Russia (9.9% of Renault's total
consolidated revenues in 2021). This includes Renault's
manufacturing plant in Moscow and the assessment of options with
regards to Renault's stake in Avtovaz, the leading automaker in
Russia. Consequently, Renault reduced its operating margin target
for 2022 to around 3% from previously more than 4%, and its free
cash flow expectation to positive from previously more than EUR1
billion. Concurrently, Renault reiterated its focus on executing
its Renaulution strategic plan.

The suspension of Renault's activities in Russia is a setback for
Renault's plan to improve profitability. In 2021, AVTOVAZ (Renault
stake: 67.69%) contributed EUR249 million or close to 50% to
Renault's automotive operating margin of EUR505 million. It was
also more profitable (8.7% return on sales) compared to Renault's
other automotive business (0.6% return on sales). In addition to
AVTOVAZ, the suspension of Renault's Moscow plant will weaken
Renault's profits and return on sales by an undisclosed amount.
Moody's understand, however, that Renault's activities in Russia
are self-contained, that Renault has not guaranteed local debt in
Russia, and that Renault will not inject cash into the country.
This means that at least AVTOVAZ's debt (EUR1.1 billion as of
December 2021) will fall away, if Renault finally discontinues its
activities in Russia. Moody's also expects that the reduction of
Renault's free cash flow expectation predominantly relates to
Russia, while the expected cash flow generation of its other
operations is largely unaffected.

Renault's leverage is high but expected to improve into Moody's
expected range for the Ba2 and become comfortably positioned from
2023. In February 2022, Renault announced the repayment of EUR2
billion of the French state-guaranteed loan (including EUR1 billion
early repayment) in 2022. Together with expected moderate EBITDA
improvements of Renault's non-Russian business, Moody's expects
Renault's leverage (Moody's adjusted debt / EBITDA) to improve to
approximately 4.0x in 2022 (5.7x in 2021), and towards 3.0x in
2023, in line with the range of 3x-4x Moody's expects for the Ba2.
The potential de-consolidation of Renault's operations in Russia
(including Renault's non-guaranteed local debt) would not have a
material impact on Renault's leverage.

For the full year 2022, Moody's expects Renault's EBITA margins
(including and excluding Nissan, Moody's adjusted) to be at the
level of 2021 (1.3%, and 0.4%, respectively), assuming that
Renault's Russian activities will be discontinued operations. For
2023, Moody's expects a positive margin development. However,
without the Russian activities, it might take Renault one
additional year to improve its margins (excluding Nissan) to at
least 2.0%, which Moody's considers as the minimum for the Ba2
rating.

RATIONALE FOR THE NEGATIVE OUTLOOK

The negative rating outlook reflects the continued weakness in
Renault's main credit metrics over the next 12-18 months as it
implements its restructuring plan and attempts to restore its
competitive position. Despite gradual improvements, it remains
challenging for Renault to improve its operating profit margins to
2% (Moody's adjusted EBITA, excluding Nissan contribution),
generate positive free cash flows in the mid- to high three-digit
million EUR amounts (Moody's adjusted, after restructuring) and
reduce Moody's adjusted Debt / EBITDA to below 4x by the end of
2022.

LIQUIDITY

Renault's liquidity profile is good. As of December 31, 2021,
Renault's principal sources of liquidity consisted of cash and cash
equivalents on the balance sheet, amounting to EUR13.9 billion;
undrawn committed credit lines of EUR3.4 billion; current financial
assets of EUR1.0 billion. Including funds from operations, which
Moody's expects to exceed EUR3 billion over the next 12 months,
liquidity sources amount to more than EUR21 billion.

These provide good coverage for liquidity requirements of around
EUR10 billion that could emerge during the next 12 months,
including short-term debt maturities of around EUR4.0 billion
(including EUR3.0 billion state-guaranteed credit loans, of which
Renault plans to repay EUR2.0 billion in 2022), expected capital
spending of slightly below EUR2 billion, and day-to-day needs
(around EUR1.5 billion).

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

Renault's ratings could be downgraded in case of (1) an inability
to restore Moody's-adjusted EBITA margin excluding the at-equity
contribution of Nissan towards 2% by 2022; (2) Moody's-adjusted
Debt/EBITDA to consistently exceed 4.0x and (3) FCF to remain
materially negative for a prolonged period. Furthermore, a
significant weakening of Renault's liquidity could also trigger a
further rating downgrade.

Although an upgrade within the next 24 months is not likely,
Moody's would consider upgrading the ratings in case of (1)
Moody's-adjusted EBITA margin excluding the at-equity contribution
of Nissan sustainably increasing towards the mid-single digits (in
percentage terms); (2) Moody's-adjusted Debt/EBITDA were to
decrease below 3.0x and (3) FCF generation were to become
sustainably positive.

LIST OF AFFECTED RATINGS:

Issuer: Renault S.A.

Affirmations:

LT Corporate Family Rating, Affirmed Ba2

Probability of Default Rating, Affirmed Ba2-PD

Senior Unsecured Medium-Term Note Program, Affirmed (P)Ba2

Senior Unsecured Regular Bond/Debenture, Affirmed Ba2

Outlook Actions:

Outlook, Remains Negative

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Automobile
Manufacturers published in May 2021.



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I R E L A N D
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AURIUM CLO IX: S&P Assigns B- (sf) Rating to Class F Notes
----------------------------------------------------------
S&P Global Ratings assigned its credit ratings to Aurium CLO IX
DAC's class A, B-1, B-2, C, D, E, and F notes. At closing, the
issuer also issued unrated subordinated notes.

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

The portfolio's reinvestment period will end approximately
four-and-a-half years after closing, and the portfolio's maximum
average maturity date will be eight-and-a-half years after
closing.

The ratings assigned to the notes reflect S&P's assessment of:

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

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

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

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

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

  Portfolio Benchmarks
                                                          CURRENT
  S&P Global Ratings weighted-average rating factor      2,839.57
  Default rate dispersion                                  385.31
  Weighted-average life (years)                              5.26
  Obligor diversity measure                                121.53
  Industry diversity measure                                17.96
  Regional diversity measure                                 1.31

  Transaction Key Metrics
                                                          CURRENT
  Portfolio weighted-average rating derived
    from S&P's CDO evaluator                                  'B'
  'CCC' category rated assets (%)                            1.25
  Covenanted 'AAA' weighted-average recovery (%)            34.90
  Covenanted weighted-average spread (%)                     3.80
  Covenanted weighted-average coupon (%)                     5.50

S&P said, "Our ratings reflect our assessment of the collateral
portfolio's credit quality, which has a weighted-average rating of
'B'. We consider that the portfolio will be well-diversified on the
effective date, primarily comprising broadly syndicated
speculative-grade senior secured term loans and senior secured
bonds. Therefore, we conducted our credit and cash flow analysis by
applying our criteria for corporate cash flow collateralized debt
obligations.

"In our cash flow analysis, we considered the EUR400 million par
amount, the covenanted weighted-average spread of 3.80%, the
covenanted weighted-average coupon of 5.50%, and the covenanted
weighted-average recovery rates for all rating levels. 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."

This transaction also features a principal transfer test, which
allows interest proceeds exceeding the principal transfer coverage
ratio to be paid into either the principal or supplemental reserve
account. The interest proceeds can only be paid into the principal
account senior to the reinvestment overcollateralization test and
into the supplemental reserve account junior to the reinvestment
overcollateralization test. Therefore, S&P has not applied a cash
flow stress for this. Nevertheless, because the transfer to
principal is at the collateral manager's discretion, S&P did not
give credit to this test in our cash flow analysis.

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

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.

"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,
B-1, B-2, C, D, E, and F notes. Our credit and cash flow analysis
indicates that the available credit enhancement for the class B-1,
B-2, C, and D notes could withstand stresses commensurate with
higher ratings than those we have assigned. However, as the CLO is
still in its reinvestment phase, during which the transaction's
credit risk profile could deteriorate, we have capped our assigned
ratings on the notes.

"Our credit and cash flow analysis of the class F notes indicates
that the available credit enhancement could withstand stresses that
are commensurate with a 'CCC' rating. However, the class F notes'
current break-even default rate (BDR) cushion is negative at the
'B-' rating level. Based on the portfolio's actual characteristics
and additional overlaying factors, including our long-term
corporate default rates and recent economic outlook, we believe
this class is able to sustain a steady-state scenario, in
accordance with our criteria. S&P's analysis reflects several
factors, including:

-- The class F notes' available credit enhancement, which is in
the same range as that of other CLOs we have rated and that have
recently been issued in Europe.

-- S&P's BDR at the 'B-' rating level, which is 25.21% versus a
portfolio default rate of 16.31% if we were to consider a long-term
sustainable default rate of 3.1% for a portfolio with a
weighted-average life of 5.3 years.

-- Whether the tranche is vulnerable to non-payment in the near
future.

-- If there is a one-in-two chance for this note to default.

-- If we envision this tranche to default in the next 12-18
months.

-- Following this analysis, we consider that the available credit
enhancement for the class F notes is commensurate with the 'B-
(sf)' rating assigned.

S&P said, "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
to E 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.

"For the class E and F notes, 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."

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 (see "ESG Industry Report Card: Collateralized Loan
Obligations," published March 31, 2021). 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 certain activities, including, but not limited to, the
following: tobacco, adult entertainment, illegal activities, forced
labor, asbestos fibers, sanctioned products, speculative extraction
of oil and gas, payday lending, production of controversial
weapons, trade in hazardous chemicals, and illegal drugs or
narcotics. Accordingly, since the exclusion of assets from these
industries does not result in material differences between the
transaction and our ESG benchmark for the sector, no specific
adjustments have been made in our rating analysis to account for
any ESG-related risks or opportunities."

  Ratings List

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

  A        AAA (sf)   248.0     38.00    Three/six-month EURIBOR  
                                         plus 0.95%

  B-1      AA (sf)     31.0     27.75    Three/six-month EURIBOR
                                         plus 1.75%

  B-2      AA (sf)     10.0     27.75    2.20%

  C        A (sf)      23.0     22.00    Three/six-month EURIBOR
                                         plus 2.5%

  D        BBB- (sf)   29.0     14.75    Three/six-month EURIBOR
                                         plus 3.50%

  E        BB- (sf)    20.0      9.75    Three/six-month EURIBOR
                                         plus 6.70%

  F        B- (sf)     13.0      6.50    Three/six-month EURIBOR
                                         plus 9.36%

  Subordinated  NR     29.0       N/A    N/A

*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.
NR--Not rated.
N/A--Not applicable.


AVOCA CLO XXVI: Fitch Gives Final 'B-' Rating to Class F Tranche
----------------------------------------------------------------
Fitch Ratings has assigned Avoca CLO XXVI DAC's final ratings.

    DEBT                    RATING             PRIOR
    ----                    ------             -----
Avoca CLO XXVI DAC

A XS2437854644       LT AAAsf    New Rating    AAA(EXP)sf
B-1 XS2437854990     LT AAsf     New Rating    AA(EXP)sf
B-2 XS2437855294     LT AAsf     New Rating    AA(EXP)sf
C XS2437855450       LT Asf      New Rating    A(EXP)sf
D XS2437855617       LT BBB-sf   New Rating    BBB-(EXP)sf
E XS2437855963       LT BB-sf    New Rating    BB-(EXP)sf
F XS2437856003       LT B-sf     New Rating    B-(EXP)sf
Subordinated Notes   LT NRsf     New Rating
XS2437856185

TRANSACTION SUMMARY

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

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch weighted average rating factor (WARF) of the identified
portfolio is 25.85.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise senior secured obligations. Fitch views the
recovery prospects for these assets as more favourable than for
second-lien, unsecured and mezzanine assets. The Fitch weighted
average recovery rate (WARR) of the identified portfolio is
62.55%.

Diversified Portfolio (Positive): The transaction includes two
Fitch matrices: one effective at closing corresponding to a top 10
obligor concentration limit at 20%, fixed-rate asset limit at 10%
and 8.5-year WAL; and one that can be selected by the manager at
any time from one year after closing as long as the portfolio
balance (including defaulted obligations at their Fitch collateral
value) is above target par and corresponding to the same limits as
the previous matrix, apart from a 7.5-year WAL.

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 portfolio with the aim of testing the robustness of the
transaction structure against its covenants and portfolio
guidelines.

Cash Flow Modelling (Positive): The WAL used for the transaction
stress portfolio and matrices analysis is 12 months less than the
WAL covenant, to account for structural and reinvestment conditions
after the reinvestment period, including the overcollateralisation
tests and Fitch 'CCC' limitation passing after reinvestment, among
other things. In Fitch's opinion, these conditions would reduce the
effective risk horizon of the portfolio during the stress period.

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 loss expectation is larger than
    initially assumed, due to unexpectedly high levels of defaults
    and portfolio deterioration.

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

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

-- 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.

DATA ADEQUACY

Avoca CLO XXVI DAC

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.

AVOCA CLO XXVI: Moody's Assigns B3 Rating to EUR11MM Class F Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to notes issued by Avoca CLO XXVI
Designated Activity Company (the "Issuer"):

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

EUR22,500,000 Class B-1 Senior Secured Floating Rate Notes due
2035, Definitive Rating Assigned Aa2 (sf)

EUR17,500,000 Class B-2 Senior Secured Fixed Rate Notes due 2035,
Definitive Rating Assigned Aa2 (sf)

EUR28,000,000 Class C Deferrable Mezzanine Floating Rate Notes due
2035, Definitive Rating Assigned A2 (sf)

EUR26,000,000 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)

EUR11,000,000 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 90% of the
portfolio must consist of senior secured obligations and up to 10%
of the portfolio may consist of senior unsecured obligations,
second-lien loans, mezzanine obligations and high yield bonds. The
portfolio is expected to be fully ramped up as of the closing date
and to comprise of predominantly corporate loans to obligors
domiciled in Western Europe.

KKR Credit Advisors (Ireland) Unlimited Company will manage the
CLO. It will direct the selection, acquisition and disposition of
collateral on behalf of the Issuer and may engage in trading
activity, including discretionary trading, during the transaction's
4.6-year reinvestment period. Thereafter, subject to certain
restrictions, purchases are permitted using principal proceeds from
unscheduled principal payments and proceeds from sales of credit
risk obligations or credit improved obligations.

In addition to the seven classes of notes rated by Moody's, the
Issuer has issued EUR31,700,000 of Subordinated Notes which are not
rated.

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

Methodology underlying the rating action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2021.

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 2021.

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

Par Amount: EUR400,000,000

Diversity Score: 56

Weighted Average Rating Factor (WARF): 2995

Weighted Average Spread (WAS): 3.78%

Weighted Average Coupon (WAC): 4.00%

Weighted Average Recovery Rate (WARR): 43.5%

Weighted Average Life (WAL): 7.5 years

HARVEST CLO XV: Moody's Affirms B1 Rating on EUR13.5MM F-R Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Harvest CLO XV DAC:

EUR41,600,000 Class B-1-R Senior Secured Floating Rate Notes due
2030, Upgraded to Aa1 (sf); previously on May 22, 2018 Definitive
Rating Assigned Aa2 (sf)

EUR5,000,000 Class B-2-R Senior Secured Fixed Rate Notes due 2030,
Upgraded to Aa1 (sf); previously on May 22, 2018 Definitive Rating
Assigned Aa2 (sf)

EUR31,500,000 Class C-R Senior Secured Deferrable Floating Rate
Notes due 2030, Upgraded to A1 (sf); previously on May 22, 2018
Definitive Rating Assigned A2 (sf)

Moody's has also affirmed the ratings on the following notes:

EUR233,400,000 Class A-1A-R Senior Secured Floating Rate Notes due
2030, Affirmed Aaa (sf); previously on May 22, 2018 Definitive
Rating Assigned Aaa (sf)

EUR30,000,000 Class A-1B-R Senior Secured Fixed Rate Notes due
2030, Affirmed Aaa (sf); previously on May 22, 2018 Definitive
Rating Assigned Aaa (sf)

EUR15,000,000 Class A-2-R Senior Secured Floating Rate Notes due
2030, Affirmed Aaa (sf); previously on May 22, 2018 Definitive
Rating Assigned Aaa (sf)

EUR24,200,000 Class D-R Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed Baa2 (sf); previously on May 22, 2018
Definitive Rating Assigned Baa2 (sf)

EUR23,100,000 Class E-R Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed Ba2 (sf); previously on May 22, 2018
Definitive Rating Assigned Ba2 (sf)

EUR13,500,000 Class F-R Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed B1 (sf); previously on May 22, 2018
Definitive Rating Assigned B1 (sf)

Harvest CLO XV DAC, originally issued in May 2016 and refinanced in
May 2018, is a collateralised loan obligation (CLO) backed by a
portfolio of mostly high-yield senior secured European and US
loans. The portfolio is managed by Investcorp Credit Management EU
Limited. The transaction's reinvestment period will end in May
2022.

RATINGS RATIONALE

The rating upgrades on the Class B-1-R, Class B-2-R and Class C-R
notes are primarily a result of the benefit of the shorter period
of time remaining before the end of the reinvestment period in May
2022.

In light of reinvestment restrictions during the amortisation
period, and therefore the limited ability to effect significant
changes to the current collateral pool, Moody's analysed the deal
assuming a higher likelihood that the collateral pool
characteristics would maintain an adequate buffer relative to
certain covenant requirements.

The key model inputs Moody's uses in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers.

In its base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: EUR443,965,102

Defaulted Securities: EUR1,458,052

Diversity Score: 59

Weighted Average Rating Factor (WARF): 2964

Weighted Average Life (WAL): 4.42 years

Weighted Average Spread (WAS) (before accounting for Euribor
floors): 3.74%

Weighted Average Coupon (WAC): 3.91%

Weighted Average Recovery Rate (WARR): 44.53%

Par haircut in OC tests and interest diversion test: none

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporates these default and recovery
characteristics of the collateral pool into its cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

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 2021.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, such as account bank and swap provider,
using the methodology "Moody's Approach to Assessing Counterparty
Risks in Structured Finance" published in May 2021. Moody's
concluded the ratings of the notes are not constrained by these
risks.

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

This transaction is subject to a high level of macroeconomic
uncertainty, which could negatively affect the ratings on the note,
in light of uncertainty about credit conditions in the general
economy. In particular, the length and severity of the economic and
credit shock precipitated by the global coronavirus pandemic will
have a significant impact on the performance of the securities. CLO
notes' performance may also be impacted either positively or
negatively by 1) the manager's investment strategy and behaviour
and 2) divergence in the legal interpretation of CDO documentation
by different transactional parties because of embedded
ambiguities.

Additional uncertainty about performance is due to the following:

Portfolio amortisation: Once reaching the end of the reinvestment
period in May 2022, the main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the collateral manager or
be delayed by an increase in loan amend-and-extend restructurings.
Fast amortisation would usually benefit the ratings of the notes
beginning with the notes having the highest prepayment priority.

Weighted average life: The notes' ratings are sensitive to the
weighted average life assumption of the portfolio, which could
lengthen as a result of the manager's decision to reinvest in new
issue loans or other loans with longer maturities, or participate
in amend-to-extend offerings. The effect on the ratings of
extending the portfolio's weighted average life can be positive or
negative depending on the notes' seniority.

Recovery of defaulted assets: Market value fluctuations in
trustee-reported defaulted assets and those Moody's assumes have
defaulted can result in volatility in the deal's
over-collateralisation levels. Further, the timing of recoveries
and the manager's decision whether to work out or sell defaulted
assets can also result in additional uncertainty. Moody's analysed
defaulted recoveries assuming the lower of the market price or the
recovery rate to account for potential volatility in market prices.
Recoveries higher than Moody's expectations would have a positive
impact on the notes' ratings.

MULCAIR SECURITIES NO. 3: S&P Assigns Prelim B+ Rating to F Notes
-----------------------------------------------------------------
S&P Global Ratings has assigned its preliminary credit ratings to
Mulcair Securities No. 3 DAC's (Mulcair's) class A, B-Dfrd, C-Dfrd,
D-Dfrd, E-Dfrd, and F-Dfrd notes. At closing, Mulcair will also
issue unrated class G, Z, and X notes.

S&P said, "Our preliminary ratings address the timely payment of
interest and the ultimate payment of principal on the class A
notes. Our preliminary ratings on the class B-Dfrd, C-Dfrd, D-Dfrd,
E-Dfrd, and F-Dfrd notes address the ultimate payment of interest
and principal on these notes. Our ratings do not address the
payment of additional note payment amounts on the class D-Dfrd,
E-Dfrd, and F-Dfrd notes."

Senior fees and interest due on the class A Dfrd notes are
supported by a senior reserve fund, which will be fully funded at
2% of the initial balance of this note class. This reserve can
amortize and has a 1% floor. Other note class interest is supported
by the general reserve fund.

Mulcair Securities No. 3 DAC is a static RMBS transaction that
securitizes a portfolio of EUR361.2 million loans, which comprises
mostly (78.1%) buy-to-let (BTL) and some owner-occupied mortgage
loans secured over residential properties in Ireland, most of which
are now performing after being restructured. They were originated
by the Bank of Ireland, ICS Building Society, and Bank of Ireland
Mortgage Bank (BOIMB). About three quarters of the pool formed part
of Mulcair Securities DAC, which closed in April 2019 and exhibited
stable performance during its life.

At closing, the issuer will use the issuance proceeds to purchase
the beneficial interest in the mortgage loans from the seller. The
issuer grants security over all its assets in favor of the security
trustee. S&P said, "We consider the issuer to be a
bankruptcy-remote entity, and we have received preliminary legal
opinions that indicate that the sale of the assets would survive
the seller's insolvency. We expect to receive confirmation of the
legal opinions before closing."

Bank of Ireland will act as servicer for all of the loans in the
transaction from the closing date. S&P has considered this in light
of its operational risk criteria, and it does not constrain our
ratings.

There are no rating constraints in the transaction under S&P's
structured finance sovereign risk criteria

S&P said, "We expect that the documented replacement triggers and
collateral posting framework under the cap agreement will support a
maximum rating of 'AAA' under our counterparty risk criteria. Our
final ratings will depend on our review of the final relevant
transaction documentation and the relevant triggers and framework
being compliant."

Although the loans in the pool were originated as prime mortgages,
arrears in the portfolio peaked at approximately 44% in 2014,
mainly due to the stressed macroeconomic environment in Ireland.
Since then, arrears have decreased in line with overall mortgage
market trends in Ireland. S&P attributes this to the improved
economy and to restructuring arrangements implemented by the
servicer.

On the closing date, the retention holder will acquire an indirect
exposure to all of the class G and Z notes in compliance with its
risk retention requirements.

  Preliminary Ratings

  CLASS     PRELIM. RATING*     CLASS SIZE (%)

  A          AAA (sf)            76.50
  B-Dfrd     AA (sf)              7.00
  C-Dfrd     A (sf)               3.50
  D-Dfrd     BBB (sf)             5.00
  E-Dfrd     BB (sf)              2.00
  F-Dfrd     B+ (sf)              1.00
  G-Dfrd     NR                   4.50
  Z          NR                   0.50
  X          NR                   2.75

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


PENTA CLO 4: Moody's Affirms B2 Rating on EUR10.45MM Class F Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Penta CLO 4 Designated Activity Company:

EUR38,000,000 Class B-1 Senior Secured Floating Rate Notes due
2030, Upgraded to Aaa (sf); previously on Jun 14, 2018 Definitive
Rating Assigned Aa2 (sf)

EUR10,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2030,
Upgraded to Aaa (sf); previously on Jun 14, 2018 Definitive Rating
Assigned Aa2 (sf)

EUR30,050,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2030, Upgraded to A1 (sf); previously on Jun 14, 2018
Definitive Rating Assigned A2 (sf)

EUR20,550,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2030, Upgraded to Baa1 (sf); previously on Jun 14, 2018
Definitive Rating Assigned Baa2 (sf)

Moody's has also affirmed the ratings on the following notes:

EUR236,000,000 Class A Senior Secured Floating Rate Notes due
2030, Affirmed Aaa (sf); previously on Jun 14, 2018 Definitive
Rating Assigned Aaa (sf)

EUR27,100,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed Ba2 (sf); previously on Jun 14, 2018
Definitive Rating Assigned Ba2 (sf)

EUR10,450,000 Class F Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed B2 (sf); previously on Jun 14, 2018
Definitive Rating Assigned B2 (sf)

Penta CLO 4 Designated Activity Company, issued in June 2018, is a
collateralised loan obligation (CLO) backed by a portfolio of
mostly high-yield senior secured European loans. The portfolio is
managed by Partners Group (UK) Management Ltd. The transaction's
reinvestment period will end in June 2022.

RATINGS RATIONALE

The rating upgrades on the Class B-1, B-2, C and D Notes are
primarily a result of the benefit of the shorter period of time
remaining before the end of the reinvestment period in June 2022.

In light of reinvestment restrictions during the amortisation
period, and therefore the limited ability to effect significant
changes to the current collateral pool, Moody's analysed the deal
assuming a higher likelihood that the collateral pool
characteristics would maintain an adequate buffer relative to
certain covenant requirements. In particular, Moody's assumed that
the deal will benefit from a shorter amortisation profile than it
had assumed at the last rating action in June 2018.

The key model inputs Moody's uses in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers.

In its base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: EUR397.4m

Defaulted Securities: EUR1.0m

Diversity Score: 59

Weighted Average Rating Factor (WARF): 2885

Weighted Average Life (WAL): 4.48 years

Weighted Average Spread (WAS) (before accounting for Euribor
floors): 3.67%

Weighted Average Coupon (WAC): N/A

Weighted Average Recovery Rate (WARR): 45.43%

Par haircut in OC tests and interest diversion test: None

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporates these default and recovery
characteristics of the collateral pool into its cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

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 2021.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, such as account bank, using the
methodology "Moody's Approach to Assessing Counterparty Risks in
Structured Finance" published in May 2021. Moody's concluded the
ratings of the notes are not constrained by these risks.

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

This transaction is subject to a high level of macroeconomic
uncertainty, which could negatively affect the ratings on the note,
in light of uncertainty about credit conditions in the general
economy. In particular, the length and severity of the economic and
credit shock precipitated by the global coronavirus pandemic will
have a significant impact on the performance of the securities. CLO
notes' performance may also be impacted either positively or
negatively by 1) the manager's investment strategy and behaviour
and 2) divergence in the legal interpretation of CDO documentation
by different transactional parties because of embedded
ambiguities.

Additional uncertainty about performance is due to the following:

Weighted average life: The notes' ratings are sensitive to the
weighted average life assumption of the portfolio, which could
lengthen as a result of the manager's decision to reinvest in new
issue loans or other loans with longer maturities, or participate
in amend-to-extend offerings. Moody's tested for a possible
extension of the actual weighted average life in its analysis. The
effect on the ratings of extending the portfolio's weighted average
life can be positive or negative depending on the notes'
seniority.

Recovery of defaulted assets: Market value fluctuations in
trustee-reported defaulted assets and those Moody's assumes have
defaulted can result in volatility in the deal's
over-collateralisation levels. Further, the timing of recoveries
and the manager's decision whether to work out or sell defaulted
assets can also result in additional uncertainty. Moody's analysed
defaulted recoveries assuming the lower of the market price or the
recovery rate to account for potential volatility in market prices.
Recoveries higher than Moody's expectations would have a positive
impact on the notes' ratings.

ST. PAUL'S CLO IV: Moody's Affirms B2 Rating on EUR14.3MM E Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by St. Paul's CLO IV Designated Activity Company:

EUR31,500,000 Class A-2A Senior Secured Floating Rate Notes due
2030, Upgraded to Aa1 (sf); previously on Oct 26, 2021 Affirmed Aa2
(sf)

EUR22,500,000 Class A-2B-R Senior Secured Fixed Rate Notes due
2030, Upgraded to Aa1 (sf); previously on Oct 26, 2021 Assigned Aa2
(sf)

EUR29,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2030, Upgraded to A1 (sf); previously on Oct 26, 2021
Affirmed A2 (sf)

Moody's has also affirmed the ratings on the following notes:

EUR289,500,000 (current outstanding balance EUR 289,276,000) Class
A-1-R Senior Secured Floating Rate Notes due 2030, Affirmed Aaa
(sf); previously on Oct 26, 2021 Assigned Aaa (sf)

EUR24,600,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed Baa2 (sf); previously on Oct 26, 2021
Affirmed Baa2 (sf)

EUR30,250,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed Ba2 (sf); previously on Oct 26, 2021
Affirmed Ba2 (sf)

EUR14,300,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2030, Affirmed B2 (sf); previously on Oct 26, 2021
Affirmed B2 (sf)

St. Paul's CLO IV Designated Activity Company, issued in October
2017, re-issued in July 2018 and refinanced in October 2021, is a
collateralised loan obligation (CLO) backed by a portfolio of
mostly high-yield senior secured European loans. The portfolio is
managed by Intermediate Capital Managers Limited. The transaction's
reinvestment period ended in October 2021.

RATINGS RATIONALE

The rating upgrades on the Class A-2A, Class A-2B-R and Class B
notes are primarily a result of the benefit of the transaction
having reached the end of the reinvestment period and the
improvement of the key credit metrics of the underlying pool since
the last rating action in October 2021.

In light of reinvestment restrictions during the amortisation
period, and therefore the limited ability to effect significant
changes to the current collateral pool, Moody's analysed the deal
assuming a higher likelihood that the collateral pool
characteristics would maintain an adequate buffer relative to
certain covenant requirements. In particular, Moody's assumed that
the deal will benefit from a shorter amortisation profile than it
had assumed at the last rating action in October 2021.

The key model inputs Moody's uses in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers.

In its base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: EUR476.71m

Defaulted Securities: none

Diversity Score: 59

Weighted Average Rating Factor (WARF): 2952

Weighted Average Life (WAL): 4.69 years

Weighted Average Spread (WAS) (before accounting for Euribor
floors): 3.89%

Weighted Average Coupon (WAC): 5.07%

Weighted Average Recovery Rate (WARR): 43.62%

Par haircut in OC tests and interest diversion test: 0.036%

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporates these default and recovery
characteristics of the collateral pool into its cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

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 2021.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, such as account bank and swap provider,
using the methodology "Moody's Approach to Assessing Counterparty
Risks in Structured Finance" published in May 2021. Moody's
concluded the ratings of the notes are not constrained by these
risks.

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

This transaction is subject to a high level of macroeconomic
uncertainty, which could negatively affect the ratings on the note,
in light of uncertainty about credit conditions in the general
economy. In particular, the length and severity of the economic and
credit shock precipitated by the global coronavirus pandemic will
have a significant impact on the performance of the securities. CLO
notes' performance may also be impacted either positively or
negatively by 1) the manager's investment strategy and behaviour
and 2) divergence in the legal interpretation of CDO documentation
by different transactional parties because of embedded ambiguities,
and 3) the additional expected loss associated with hedging
agreements in this transaction which may also impact the ratings
negatively.

Additional uncertainty about performance is due to the following:

Portfolio amortisation: The main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the collateral manager or
be delayed by an increase in loan amend-and-extend restructurings.

Fast amortisation would usually benefit the ratings of the notes
beginning with the notes having the highest prepayment priority.



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

POPOLARE BARI 2017: Moody's Cuts EUR80.9MM Cl. A Notes Rating to B2
-------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three notes
in Popolare Bari NPLs 2016 S.r.l. and Popolare Bari NPLs 2017
S.r.l. These downgrades reflect lower than anticipated cash-flows
generated from the recovery process on the non-performing loans
(NPLs) which translates into a reduced credit enhancement of the
notes in recent payment dates.

Issuer: Popolare Bari NPLs 2016 S.r.l.

EUR126.5M Class A Notes, Downgraded to B1 (sf); previously on Jun
11, 2021 Downgraded to Ba2 (sf)

EUR14M Class B Notes, Downgraded to Caa3 (sf); previously on Jun
11, 2021 Downgraded to Caa2 (sf)

Issuer: Popolare Bari NPLs 2017 S.r.l.

EUR80.9M Class A Notes, Downgraded to B2 (sf); previously on Jun
17, 2021 Downgraded to B1 (sf)

RATINGS RATIONALE

The rating action is prompted by lower than anticipated cash-flows
generated from the recovery process on the NPLs resulting in a
reduced credit enhancement in recent payment dates in both deals.

Lower than anticipated cash-flows generated from the recovery
process on the NPLs:

The portfolios are mainly concentrated in the South of Italy and
Islands (70.6% in Popolare Bari NPLs 2016 S.r.l. as of November
2021, and 57.0% in Popolare Bari NPLs 2017 S.r.l. as of September
2021).

Borrower concentration: about 12.2% of the pool in Popolare Bari
NPLs 2016 S.r.l. by Gross Book Value (GBV) is concentrated on the
top 10 obligors which increases potential performance volatility.
The concentration is already significant in Popolare Bari NPLs 2017
S.r.l., at 32.9%.

Industrial concentration: about 31.4% of the secured pool in
Popolare Bari NPLs 2016 S.r.l. is backed by industrial properties,
a higher exposure than its peers. Recoveries from this type of
properties are volatile, especially for big industrial buildings.

For Popolare Bari NPLs 2016 S.r.l., cumulative gross collections
represent 16.1% of the original GBV as of November 2021. As of
November 2021, the Cumulative Collection Ratio was at 65%, below
the limit for a subordination event at 90%. A low Cumulative
Collection Ratio as in this case means collections are coming
slower than anticipated. The NPV Cumulative Profitability Ratio was
at 95%. NPV Cumulative Profitability ratio is the ratio between the
Net Present Value of collections for exhausted debt relationship,
discounted at 3.5% yield, against the expected collections as per
the original business plan. Unpaid interest on Class B is EUR1.6
million as of November 2021, since the subordination event was hit
in May 2020.

For Popolare Bari NPLs 2016 S.r.l., in terms of the underlying
portfolio, the reported GBV stood at EUR338.04 million as of
November 2021 down from EUR479.89 million at closing. Out of the
approximately EUR140 million reduction of GBV since closing,
principal payments to Class A have been in the range of EUR52
million. The secured portion has decreased to 55.3% from 63.4% at
closing. 770 properties, representing around 37% of the assets
backing the initial pool by value, have been sold at 54% of the
updated property values on average as of closing but showing a
decline for properties sold since 2018. Overall profitability for
closed positions calculated as the ratio between recoveries and
balance of write-offs (total recoveries plus losses) is 35%, in the
low range of Italian NPL securitisations Moody's rate.

The latest business plan received in 2021 contemplates cumulative
gross collections below the 41% of the GBV contemplated in the
original business plan.

For Popolare Bari NPLs 2017 S.r.l., in terms of the underlying
portfolio, the reported GBV stood at EUR278.58 million as of
September 2021 down from EUR319.69 million at closing. Out of the
approximately EUR41 million reduction of GBV since closing,
principal payments to Class A have been in the range of EUR17.5
million. The secured portion has decreased to 52.8% from 55.9% at
closing. Around 125 properties, representing approximately 27% of
the assets backing the initial pool by value, have been sold at 44%
of the updated property values as of closing, a relatively low
level. Overall profitability for closed positions is 51%.

For Popolare Bari NPLs 2017 S.r.l., the Cumulative Collection Ratio
was at 46.0% as of September 2021. The NPV Cumulative Profitability
Ratio was at 89.76%, below the trigger of 90% for the first time.
This has triggered the deferral of interest for Class B Notes.

The latest business plan received in 2021 contemplates cumulative
gross collections below the 38% of the GBV contemplated in the
original business plan. The collections remained subdued in most
recent payment date in October 2021, with the Class A not receiving
principal payment due to insufficient collections, compared to the
outstanding amount of Class A at EUR63.4 million. As a result of
that, the cash reserve is not fulling funded, with a shortfall of
EUR0.7M.

Deterioration of the level of credit enhancement in recent payment
dates:

The lower than expected recovery rate translates into a reduced
credit enhancement of all rated notes in both deals.

For Popolare Bari NPLs 2016 S.r.l., Moody's notes that the advance
rate of Class A at 21.8% as of November 2021 is flat compared to
21.8% as of November 2020 and higher than the 21.6% observed in May
2020. This is the ratio between the outstanding amount of the Class
A and the gross book value. Simulation of cashflows from the
remaining pool in light of portfolio characteristics, coupled with
the outstanding balance of the Class A and Class B Notes are no
longer consistent with the ratings prior to the downgrades.

For Popolare Bari NPLs 2017 S.r.l., Moody's notes that the advance
rate of Class A at 22.74% as of October 2021 is slightly higher
than the 22.35% observed in April 2021, and overall flat in past
payment dates. Simulation of cashflows from the remaining pool in
light of portfolio characteristics, coupled with the outstanding
balance of the Class A Notes are no longer consistent with the
rating prior to the downgrade.

NPL transactions' cash flows depend on the timing and amount of
collections. Due to the current economic environment, Moody's has
considered additional stresses in its analysis, including a 6 to
12-month delay in the recovery timing.

Moody's has taken into account the potential cost of the GACS
Guarantee within its cash flow modelling, while any potential
benefit from the guarantee for the senior Noteholders has not been
considered in its analysis.

The action has considered how the coronavirus pandemic has reshaped
Italy's economic environment and the way its aftershocks will
continue to reverberate and influence the performance of NPLs.
Moody's expect the public health situation to improve as
vaccinations against COVID-19 increase and societies continue to
adapt to new protocols. But the virus will remain endemic, and
economic prospects will vary – starkly, in some cases – by
region and sector.

Moody's regard the coronavirus outbreak as a social risk under its
ESG framework, given the substantial implications for public health
and safety.

The principal methodology used in these ratings was "Non-Performing
and Re-Performing Loan Securitizations Methodology" published in
April 2020.

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

Factors or circumstances that could lead to an upgrade of the
ratings include: (i) the recovery process of the non-performing
loans producing significantly higher cash-flows in a shorter time
frame than expected; (ii) improvements in the credit quality of the
transaction counterparties; and (iii) a decrease in sovereign
risk.

Factors or circumstances that could lead to a downgrade of the
ratings include: (i) significantly lower or slower cash-flows
generated from the recovery process on the non-performing loans due
to either a longer time for the courts to process the foreclosures
and bankruptcies, a change in economic conditions from Moody's
central scenario forecast or idiosyncratic performance factors. For
instance, should economic conditions be worse than forecasted and
the sale of the properties generate less cash-flows for the issuer
or take a longer time to sell the properties, all these factors
could result in a downgrade of the ratings; (ii) deterioration in
the credit quality of the transaction counterparties; and (iii)
increase in sovereign risk.



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

DOMI 2022-1: S&P Assigns Prelim B- (sf) Rating on Class X Notes
---------------------------------------------------------------
S&P Global Ratings has assigned preliminary credit ratings to Domi
2022-1 B.V.'s class A and B-Dfrd to X-Dfrd interest deferrable
notes. At closing, Domi 2022-1 will also issue unrated class Z
notes.

Domi 2022-1 is a static RMBS transaction that securitizes a
portfolio of EUR350.854 million buy-to-let mortgage loans (as of
Dec. 31, 2021) secured on properties in the Netherlands. The loans
in the pool were originated by Domivest B.V. between 2020 and 2021.
It will be the fifth in the series of Domi RMBS securitizations.

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

Credit enhancement for the rated notes will consist of
subordination from the closing date.

The transaction will feature a general reserve fund to provide
liquidity.

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

  Preliminary Ratings

  CLASS    PRELIM. RATING*    CLASS SIZE (%)

  A         AAA (sf)           89.50

  B-Dfrd    AA (sf)             4.00

  C-Dfrd    AA- (sf)            2.50

  D-Dfrd    BBB- (sf)           2.50

  E-Dfrd    B- (sf)             1.50

  X-Dfrd    B- (sf)             3.00

  Z         NR                  N/A

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


DOMI BV 2022-1: Moody's Assigns (P)Caa2 Rating to EUR10MM X Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
Notes to be issued by Domi 2022-1 B.V.:

EUR[298.500]M Class A Mortgage Backed Floating Rate Notes due
April 2054, Assigned (P)Aaa (sf)

EUR[13.300]M Class B Mortgage Backed Floating Rate Notes due April
2054, Assigned (P)Aa2 (sf)

EUR[8.300]M Class C Mortgage Backed Floating Rate Notes due April
2054, Assigned (P)A1 (sf)

EUR[8.300]M Class D Mortgage Backed Floating Rate Notes due April
2054, Assigned (P)Baa2 (sf)

EUR[5.000]M Class E Mortgage Backed Floating Rate Notes due April
2054, Assigned (P)Caa3 (sf)

EUR[10.000]M Class X Mortgage Backed Floating Rate Notes due April
2054, Assigned (P)Caa2 (sf)

Moody's has not assigned a provisional rating to the EUR[0]M Class
Z Notes due April 2054.

RATINGS RATIONALE

The Notes are backed by a static pool of Dutch buy-to-let ("BTL")
mortgage loans originated by Domivest B.V. ("Domivest"). This
represents the fifth issuance of this originator.

The total provisional portfolio as of January 31, 2022 is EUR350.8
million, from which the securitized pool of around EUR333.310
million is randomly selected at closing (the balance being retained
by Domivest). The Reserve Fund is funded at [0.75]% of the Notes
balance of Class A at closing with a target of [1.5]% of Class A
Notes balance until the step-up date. The total credit enhancement
for the Class A Notes at closing will be roughly [10.5]% in
addition to excess spread and the credit support provided by the
reserve fund.

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

According to Moody's, the transaction benefits from various credit
strengths such as a static portfolio and an amortising reserve fund
sized on aggregate at closing at [0.75]% of Class A Notes'
principal amount. However, Moody's notes that the transaction
features some credit weaknesses such as a small and unregulated
originator also acting as master servicer and the focus on a small
and niche market, the Dutch BTL sector. Domivest B.V. with its
current size and set-up acting as master servicer of the
securitised portfolio would not have the capacity to service the
portfolio on its own. However, the day-to-day servicing of the
portfolio is outsourced to Stater Nederland B.V. ("Stater", NR) as
subservicer and HypoCasso B.V. (NR, 100% owned by Stater) as
delegate special servicer. Stater and HypoCasso B.V. are obliged to
continue servicing the portfolio after a master servicer
termination event. This risk of servicing disruption is further
mitigated by structural features of the transaction. These include,
among others, the issuer administrator acting as a backup servicer
facilitator who will assist the issuer in appointing a back-up
servicer on a best effort basis upon termination of the servicing
agreement.

Moody's determined the portfolio lifetime expected loss of [2.0]%
and Aaa MILAN credit enhancement ("MILAN CE") of [16.0]% related to
the mortgage portfolio. The expected loss captures Moody's
expectations of performance considering the current economic
outlook, while the MILAN CE captures the loss Moody's expect the
portfolio to suffer in the event of a severe recession scenario.
Expected loss and MILAN CE are parameters used by Moody's to
calibrate its lognormal portfolio loss distribution curve and to
associate a probability with each potential future loss scenario in
the ABSROM cash flow model to rate RMBS.

Portfolio expected loss of [2.0]%: This is higher than the average
in the Dutch RMBS sector and is based on Moody's assessment of the
lifetime loss expectation for the pool taking into account: (i)
that little historical performance data for the originator's
portfolio is available; (ii) benchmarking with comparable
transactions in the Dutch owner-occupied market and the UK BTL
market; (iii) peculiarities of the Dutch BTL market, such as the
relatively high likelihood that the lender will not benefit from
its pledge on the rents paid by the tenants in case of borrower
insolvency; and (iv) the current stable economic conditions and
forecasts in The Netherlands.

The MILAN CE for this pool is [16.0]%: Which is higher than that of
other RMBS transactions in The Netherlands mainly because of: (i)
the fact that no meaningful historical performance data is
available for the originator's portfolio and the Dutch BTL market;
(ii) the weighted average current loan-to-market value (LTMV) of
approximately [73.2]%; and (iii) the high interest only (IO) loan
exposure (all loans are IO loans after being repaid to 75.0% LTV).
Moody's also considered the high maturity concentration of the
loans as more than 79% repay within the same year. Borrowers could
be unable to refinance IO loans at maturity because of the lack of
alternative lenders. Furthermore, while Domivest is using the
market value in rented status in assessing the LTV upon
origination, Moody's apply an additional stress to the property
values to account for the higher illiquidity of rented-out
properties when being foreclosed and sold in rented state in a
severe stress scenario. Due to the small and niche nature of the
Dutch BTL market and the high tenant protection laws in The
Netherlands Moody's consider a higher likelihood that properties
will have to be sold with tenants occupying the property than in
other BTL markets, such as UK.

The principal methodology used in these ratings was "Moody's
Approach to Rating RMBS Using the MILAN Framework" published in
February 2022.

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

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

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

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

PEER HOLDING: S&P Raises LT ICR to 'BB-', Outlook Stable
--------------------------------------------------------
S&P Global Ratings raised its long-term issuer credit and issue
ratings on value retailer Action's (an operating subsidiary of Peer
Holding III B.V.) parent Peer Holding III B.V. and its senior
secured debt to 'BB-' from 'B+' and revised its recovery rating on
the debt to '3' from '4'.

The stable outlook reflects S&P's view that Action can continue to
expand its store network, resulting in strong sales growth, robust
margins, and increasing cash generation.

Action has seen robust performance to date, spurred by a strong
organic growth and record store openings.

S&P said, "The company's stores were less severely affected by
COVID-19 restrictions in 2021, which led to like-for-like revenue
growth of 11% compared to a 1.4% contraction in 2020. In our view,
this was largely spurred by strong demand and structurally better
performance. At the same time, Action opened a net 267 stores, the
majority in its key markets of France; Belgium, the Netherlands,
and Luxembourg (Benelux); Germany; and Poland. This resulted in
total reported revenue growth of 21%. S&P Global Ratings-adjusted
EBITDA margins were also exceptionally high, spurred by operating
leverage, at about 15.5% compared with 13.9% in 2020. Although we
believe that Action can pass on a significant amount of
inflation-related costs, we expect EBITDA margins will normalize to
about 14.2%-14.7% in 2022."

The company holds strong positions as the leading value discounter
in Benelux, with improving scale and geographical diversification
that will support earnings resilience. Action is a leading general
merchandise discounter in Benelux while its rising geographical
diversification provides growth potential and increasing scale. The
company has been operating in larger European markets such as
France and Germany for many years, as well as in Poland and
Austria. It also more recently entered the Czech Republic, Italy,
and Spain. The strong sales growth of over 21% during 2021 includes
like-for-like store sales growth of 11% and revenue from store
expansion of 10%, supporting S&P's view of the group's unique value
proposition and a consumer shift toward discount retailers.

Action is unrivaled in retail store expansion and maintaining
profitability. Action expanded to 1,983 stores in 2021 from 406 in
2013, with 216 openings a year during 2016-2020 and net 267 last
year. It also increased company-defined operating EBITDA margin
(pre-International Financial Reporting Standard 16) to 12.1% from
11.6% in 2016. All newly opened stores turned profitable almost
immediately, with a very low historical payback period on
investment of about one year. Furthermore, efficient inventory
management and a high cash flow conversion rate support funding of
new store openings without increasing financial risk. With plans to
enter neighboring European markets and still-material gaps in large
retail markets, such as France and Germany, S&P believes that the
group has compelling growth potential over the medium term.

The expansion strategy means material investment needs and
execution risk remain. Although existing warehouses have sufficient
capacity to cover projects planned for 2022, S&P expects that
additional investment is needed to support likely further expansion
throughout Europe. Given the rapid expansion into new markets such
as the Czech Republic, Italy, and now Spain, we also see general
execution risk relating to immediately meeting different consumer
tastes throughout Europe and undertaking future expansion
profitably. At the same time, S&P acknowledges that the company's
entries into France, Germany, Poland, and Austria were successful
and well accepted by customers.

The consumer shift toward discount retailers benefits Action in an
otherwise competitive market. Discount retailers like Action, B&M
Value Retail (U.K.), and Dollar General (U.S.) have expanded
considerably over the past five years through their low-price
offerings. S&P forecasts real consumption growth of 3.0%-4.5% per
year until 2023 and expect about 5% inflation for 2022. The rising
cost of living increases the appeal of discount stores. That said,
we see intense competition from specialty stores and food
discounters selling general merchandise. Food discounters such as
Aldi and Lidl have expanded their nonfood assortment and wield
significant scale and negotiating power with suppliers to achieve
very competitive prices in a market where this is a main
differentiation point for customers.

Quick deleveraging potential is limited by the financial policy and
frequent dividend recapitalizations. Commensurate with the
financial policy of its majority owners, funds owned or managed by
private-equity sponsor 3i, Action has a track record of frequent
dividend payouts. Over the past five years, three major dividend
recapitalizations pushed S&P Global Ratings-adjusted leverage to
about 5x debt to EBITDA, but Action has consistently deleveraged to
about 4.5x within about a year of each transaction, solely through
its operating performance and growth. In 2021 and the beginning of
2022 the sponsor received dividends of about EUR660 million,
leaving pro-forma cash of EUR422 million at year-end 2021.

The company's strong free operating cash flow (FOCF) supports the
rating. Given Action's solid profitability and efficient working
capital management, we see the group as very cash generative. S&P
does not net the EUR759 million in cash on the balance sheet at
year-end 2021 from our calculation of adjusted debt considering the
frequent dividend payments. Nevertheless, with adjusted FOCF to
debt consistently at about 10%, and more than 15% in 2021, cash
flow is stronger than that of similarly rated peers.

S&P said, "Our improved recovery rating of '3' (60%) from '4' (45%)
is due to Action's increased scale, further growth potential, and
geographical diversification. We recognize that Action has gained
significant scale over the past few years, increasing revenue to
EUR6.8 billion from EUR4.2 billion in 2018 while also reducing its
exposure to the Netherlands to 21% of revenue in 2021 from 33% over
the same period. Given its track record, we expect international
earnings growth to continue and, therefore, we increased our
valuation at hypothetical default in 2026.

"The stable outlook reflects our view that Action can continue to
expand its store network, resulting in strong sales growth, robust
margins, and increasing cash generation. It also takes into account
the historical financial policy and expected debt to EBITDA of
about 4.0x-5.0x, within 12 months following a recapitalization."

S&P could raise its rating on Action, if:

-- It performs in line with S&P's expectations, with scale and
geographical diversification improving and S&P Global
Ratings-adjusted EBITDA margin maintained above 14.5%.

-- The group maintains S&P Global Ratings-adjusted debt to EBITDA
well below 5x on a sustainable basis.

-- Reported FOCF after leases remains significantly above EUR300
million.

-- Any positive rating change would require a clearer and more
conservative financial policy commitment from the sponsor.

S&P could lower its rating on Action over the next 12-18 months,
if:

-- Operating performance falls short of our base case such that
revenue growth collapses or profitability materially declines.

-- The group does not consistently maintain reported FOCF after
leases of about EUR300 million.

-- A more aggressive financial policy or an unexpected earnings
shortfall result in leverage rising sustainably above 5.0x.

ESG credit indicators: E-2, S-2, G-3

S&P said, "Governance factors are a moderately negative
consideration in our credit rating analysis of Peer Holding III
B.V., as is the case for most rated entities owned by
private-equity sponsors. We believe the company's highly leveraged
financial risk points to corporate decision-making that prioritizes
the interests of the controlling owners. This also reflects
generally finite holding periods and a focus on maximizing
shareholder returns."




=============
R O M A N I A
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ALPHA BANK: Moody's Ups LT Deposit Ratings to Ba1, Outlook Stable
-----------------------------------------------------------------
Moody's Investors Service has upgraded the long-term deposit
ratings of Alpha Bank Romania S.A. (ABR) to Ba1 from Ba2, and
changed the outlook on these to stable from positive. Concurrently,
Moody's has upgraded the bank's Baseline Credit Assessment (BCA)
and Adjusted BCA to ba3 from b1, its Counterparty Risk Assessment
(CR Assessment) to Baa3(cr)/P-3(cr) from Ba1(cr)/NP(cr) and its
Counterparty Risk Ratings (CRRs) to Baa3/P-3 from Ba1/NP. Further,
the rating agency affirmed the short-term deposit ratings at NP.

The rating action was triggered by the rating action on ABR's
parent bank, Alpha Bank S.A. (Alpha Bank).

RATINGS RATIONALE

  UPGRADE OF BCA

The upgrade of ABR's BCA to ba3 from b1 reflects the recent upgrade
of its parent bank's BCA to b2 from b3, as a the result of an
improvement in parent Alpha Bank's credit profile. The stronger
creditworthiness of Alpha Bank reduces risks for its subsidiary
ABR, which stem contagion risks because of existing financial and
operational linkages between ABR and Alpha Bank. These linkages had
constrained the BCA of ABR, which absent of contagion risk
considerations was already commensurate with a higher BCA.

ABR's BCA reflects its unchanged strong capitalisation, improving
loan book quality evidenced by declining non-performing loans,
stronger liquidity buffers and robust growth in customer deposits
that have also translated into reduced reliance on intragroup
funding. The BCA incorporates high asset risks, stemming from its
sizeable exposure to the cyclical commercial real estate sector and
foreign currency lending, weaker-than-peers profitability metrics,
as well as a high share of foreign currency deposits and sizeable
exposures to more confidence-sensitive corporate deposits.

  UPGRADE OF RATINGS

The upgrade of ABR's long-term deposit ratings to Ba1 from Ba2
reflects the upgrade of the bank's BCA to ba3 from b1, unchanged
two notches of uplift from Moody's Advanced Loss Given Failure
(LGF) analysis, which indicates a very low loss given failure for
deposits and low government support resulting in no rating uplift
given the bank's small domestic market share and relatively low
importance to the Romanian banking system.

The upgrade of ABR's CRRs and CR Assessment also follows the
upgrade of the BCA and reflects an unchanged loss severity for
these instrument classes as indicated by Moody's Advanced LGF
analysis.

  OUTLOOK CHANGE TO STABLE

The stable outlook reflects Moody's expectation that ABR's
intrinsic financial strength remains broadly unchanged, that a
significant strengthening of its creditworthiness is unlikely over
the outlook horizon, and that its liability structure will not
materially change, such that the loss given failure results remain
at current level.

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

ABR's ratings could be upgraded following a combination of ABR
sustainably improving its operating performance – including
improvements in profitability and asset quality – and a further
strengthening in Alpha Bank's credit profile as evident by an
upgrade of Alpha Bank's BCA. A higher uplift resulting from Moody's
Advanced LGF analysis owing to additional volume of senior or
subordinated instruments, which would increase the loss-absorption
buffer for depositors translating into lower losses in resolution,
could also result in an upgrade of the bank's deposit ratings.

ABR's ratings could be downgraded following a weakness in its
standalone credit profile that may result from deteriorating
operating conditions placing pressure on its asset quality, capital
and profitability metrics, or if Alpha Bank's BCA were to be
downgraded and thereby increasing contagion risks were to constrain
ABR's BCA. The bank's long-term deposit ratings could also be
downgraded due to changes in its liability structure, such that it
was to reduce the loss-absorption buffer for depositors, resulting
in a lower uplift from Moody's Advanced LGF analysis.

LIST OF AFFECTED RATINGS

Issuer: Alpha Bank Romania S.A.

Upgrades:

Long-term Counterparty Risk Ratings, upgraded to Baa3 from Ba1

Short-term Counterparty Risk Ratings, upgraded to P-3 from NP

Long-term Bank Deposits, upgraded to Ba1 from Ba2, outlook changed
to Stable from Positive

Long-term Counterparty Risk Assessment, upgraded to Baa3(cr) from
Ba1(cr)

Short-term Counterparty Risk Assessment, upgraded to P-3(cr) from
NP(cr)

Baseline Credit Assessment, upgraded to ba3 from b1

Adjusted Baseline Credit Assessment, upgraded to ba3 from b1

Affirmations:

Short-term Bank Deposits, affirmed NP

Outlook Action:

Outlook changed to Stable from Positive

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Banks
Methodology published in July 2021.



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

[*] RUSSIA: Makes Debt Payment in Rubles, Default Likely
--------------------------------------------------------
Ken Sweet at The Associated Press reports that Russia said on April
6 that it made a debt payment in rubles this week, a move that may
not be accepted by Russia's foreign debt holders and could put the
country on a path to an historic default.

According to the AP, the Ministry of Finance said in a statement
that it tried to make a US$649 million payment toward two bonds to
an unnamed U.S. bank -- previously reported as JPMorgan Chase --
but that payment was not accepted because new U.S. sanctions
prohibit Russia from using U.S. banks to pay its debts.

Russia said it has instead transferred the funds in rubles into a
special bank account with Russia's National Settlement Depository,
the country's securities regulator, the AP relates.  The ministry
added that once the country is allowed to access foreign exchange
markets -- not something that will happen for the foreseeable
future due to sanctions -- it will decide whether to allow
bondholders to convert the ruble payment back into dollars or
euros, the AP notes.

While Russia has 30 days of leeway to catch up with its payments,
investors have been betting on a default.  The contracts governing
Russia's bonds require in most cases payment in euros or dollars
with few and narrow exceptions known as an alternative payments
clause.  Russia contends that it has met those exceptions but
sovereign debt experts have argued otherwise, according to the AP.

"It is not clear to me, even if the clause is there, that Russia
would be entitled to use it," the AP quotes G. Mitu Gulati, a
professor at the University of Virginia School of Law and an expert
on sovereign debt restructurings and contracts, as saying in an
email.  "That's a debatable question.  I'd argue that they are not.
But this would be a question for a court."

Ratings agencies like Standard & Poor's have downgraded Russia's
debt deep into "junk" status and said a default is highly likely,
the AP relates.

While Russia has signaled it remains willing to pay its debts, the
Kremlin warned that if sanctions stayed in place, it would continue
to pay debt holders in rubles instead of dollars or euros, the AP
notes.




===========
S E R B I A
===========

HIP AZOTARA: Commences Trial Production Following Acquisition
-------------------------------------------------------------
Branislav Urosevic at SeeNews reports that Serbian fertilizer maker
HIP Azotara, which went bankrupt while in state ownership and
subsequently had its assets acquired by local company Promist, has
started trial production at its plant in Pancevo, local media
reported on April 7.

According to SeeNews, the first test run will include production of
ammonia, the Tanjug news agency reported, citing unnamed sources.

In the following trials, the plant will start production of liquid
fertilizers, SeeNews discloses.

State-controlled HIP Azotara filed for bankruptcy in 2018, SeeNews
relates.  In May 2021, its assets were acquired by Serbian company
Promist for RSD650 million (US$6.01 million/EUR5.52 million),
SeeNews states.




===========
S W E D E N
===========

UNIQUE BIDCO: Moody's Assigns First Time 'B2' Corp. Family Rating
-----------------------------------------------------------------
Moody's Investors Service has assigned a first-time B2 corporate
family rating and B2-PD probability of default rating to Unique
BidCo AB ("Optigroup" or "the company"), a Sweden-based European
distributor of business-to-business products. Concurrently, Moody's
has assigned B2 ratings to the proposed EUR515 million senior
secured term loan B1 (TLB), EUR75 million senior secured delayed
draw term loan B2 (DDTLB) and EUR60 million senior secured
revolving credit facility (RCF) to be borrowed by Unique BidCo AB.
The outlook is stable.

The proceeds from the proposed transaction will be used to finance
the acquisition of Optigroup and Hygos BV (Hygos) and pay
transaction costs.

"Optigroup's B2 rating reflects the company's well-established and
diversified position as a European business-to-business (B2B)
distributor of business essentials in the Nordics and Benelux
region, with good growth prospects", says Eric Kang, a Moody's
Vice-President - Senior Analyst. The rating also incorporates
Optigroup's high leverage, with an opening Moody's-adjusted debt /
EBITDA ratio pro forma the transaction of around 5.7x, which
positions the company adequately in its rating category, although
deleveraging is likely to be constrained by its acquisitive policy
adds Mr. Kang.

RATINGS RATIONALE

Optigroup's B2 CFR primarily reflects (1) its strong position in
the European B2B distribution of business essentials such as
cleaning, safety or packaging products, with leading market shares
in the Nordics and the Netherlands; (2) good product
diversification with operations in four distinct segments; (3) good
liquidity supported by strong free cash flow (FCF) generation with
above EUR40 million of FCF expected in 2022 and limited working
capital and capital spending requirements; (4) good growth
prospects with good underlying trends in the segments.

At the same time, the rating is constrained by (1) the company's
high opening leverage estimated at 6.0x pro forma the transaction;
(2) integration risk with the Hygos acquisition, which is much
larger than Optigroup's previous acquisitions; (3) declining demand
in the traditional paper industry; (4) governance considerations,
which are a key rating driver under Moody's ESG framework, since
Optigroup's financial policy is to be acquisitive and the company
has a limited track record operating under the company's current
form, which includes higher debt than in the past and the entry in
a new segment (medical).

The rating also reflects Optigroup's resilient performance during
the pandemic, mainly from its Facility, Safety, Food Service and
Medical segments. Increasing demand for covid-related products led
to higher prices and margins. However, Moody's expect a
normalization in the next 12 to 18 months as demand subsides. The
rating also reflects the potentially negative impact on Optigroup's
revenue of declining paper demand due to social trends such as
digitalization and an increasing number of people working from
home. This is a key rating driver and considered a social risk
under Moody's ESG framework.

Moody's does not expect the military conflict in Ukraine to have a
material impact on Optigroup's operations given its very small
exposure to Ukraine and Russia (below 0.5% of total revenue).
Moody's understands that the company has already introduced
surcharges or price increases in some business units to offset cost
inflation.

LIQUIDITY

Proforma the proposed transaction, Moody's views Optigroup's
liquidity as good. Despite a limited cash balance of EUR15 million
at closing, Moody's expects the group to generate above EUR40
million of free cash flow in 2022, based on strong EBITDA
generation and limited capital spending of around EUR10 million.
The seasonality of Optigroup's business is low and Moody's
estimates that company needs around EUR50 million to run its
operations. Liquidity is also supported by a EUR60 million senior
secured revolving credit facility (RCF) expected to remain undrawn,
and no material debt maturing before August 2028, when the revolver
matures. Optigroup's proposed senior secured TLB is due in February
2029.

ESG CONSIDERATIONS

In terms of corporate governance, Optigroup is controlled by FSN
Capital Partners, which, as is often the case in levered
private-equity deals, can have higher tolerance for leverage and
comparatively less transparent governance. The company has pursued
an acquisitive strategy in recent years, which Moody's expects will
continue in the next 24 months, potentially with the raising of
additional debt. However, this is mitigated by the loan
documentation, which allows drawing on the senior secured DDTLB
facility under the condition that leverage remains under its
opening level.

STRUCTURAL CONSIDERATIONS

The CFR is assigned to Unique BidCo AB, which is the top entity of
the restricted group and the borrower of the senior secured bank
credit facilities. The capital structure consists of a senior
secured TLB for a total amount of EUR515 million, a EUR60 million
senior secured RCF, and a EUR75 million senior secured DDTLB. The
facilities benefit from the same maintenance guarantor package,
representing around 80% of the company's consolidated EBITDA. The
facilities are secured by share pledges in the company and material
bank accounts.

The senior secured TLB, DDTLB and RCF are rated B2, in line with
the CFR, reflecting the fact that these represent the only
financial debt in the company's capital structure. Optigroup's PDR
is B2-PD, reflecting the use of a 50% family recovery rate,
consistent with a debt structure composed of senior secured bank
debt only, with a relatively weak financial maintenance covenant.
The maintenance covenant is a senior secured net leverage springing
covenant set at 8.1x, flat over the life of the facilities, and
tested every quarter. The company will have ample EBITDA headroom
at closing of the transaction.

RATIONALE FOR THE STABLE OUTLOOK

The stable outlook reflects Moody's expectation that Optigroup will
maintain its good current operating performance with low
single-digit growth in revenue, while successfully carrying out the
integration of Hygos. Moody's expects adjusted EBITDA to increase
despite current cost inflation, leading to a leverage ratio
slightly declining toward 5.5x in the next 12 to 18 months. Moody's
also expects the company to generate positive free cash flows and
to maintain a good liquidity profile.

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

Positive pressure on the rating could occur if the company
continues to successfully execute its strategy including bolt on
acquisitions. Quantitatively, upward pressure could arise if the
company displays sustained growth in sales and earnings, its
Moody's-adjusted debt/EBITDA ratio falls below 5.0x and its free
cash flow to debt increases to high single digits on a sustainable
basis. An upgrade would also require Optigroup to demonstrate a
balanced financial policy.

Conversely, negative pressure on the rating could materialise in
case of difficulties to integrate Hygos or if performance
deteriorates, leading to Optigroup's debt/EBITDA ratio exceeding
6.0x on a sustainable basis. Downward ratings pressure could also
arise if FCF or liquidity materially weakens.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Distribution &
Supply Chain Services Industry published in June 2018.

COMPANY PROFILE

Headquartered in Molndal, Sweden, Optigroup is B2B distributor of
business essentials. The company primarily focuses on the Nordics
and Benelux markets, with a wide variety of customers from SMEs to
large international companies. In the last twelve months ended
October 2021, Optigroup reported EUR1.3 billion in net sales and
EUR96 million in EBITDA (as adjusted by the company, pre-IFRS 16),
pro forma the Hygos acquisition. During the same period, Sweden
represented approximately 30% of group net sales, while the
remainder was generated in the Netherlands (24%), in other Nordics
(23%) and in the rest of Europe (23%).



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

AMIGO PLC: Creditors Can Vote on Two Schemes of Arrangement
-----------------------------------------------------------
Melanie Moore -- melanie.moore@pinsentmasons.com -- of Pinsent
Masons disclosed that creditors of subprime lender Amigo will get
the chance to consider and vote on two alternative proposals for
schemes of arrangement after the High Court in London granted leave
to convene the relevant creditor meetings.

Last year, the High Court rejected a previous proposal by Amigo
after the Financial Conduct Authority (FCA) objected to the scheme.
The concept of dual schemes being proposed and voted on is novel
and indicative of the court's efforts to ensure that restructuring
tools like schemes of arrangement are flexible.

   * Approval follows rejection of Amigo's previous scheme proposal
at sanction stage

   * First time court has considered and approved convening
meetings in respect of two concurrent, but alternative, schemes of
arrangement

   * ALL Scheme Limited, Re [2022] EWHC 549 (Ch) (15 March 2022)

This restructuring proposal was seen by many as Amigo's last chance
to avoid insolvency so perhaps it remains to be seen whether this
dual scheme approach will be widely utilised in the future.

Background

The Amigo group (Amigo) is a well-established subprime provider of
guarantor loans to those unable to borrow from mainstream lenders
due to their credit histories. Following a number of consumer
complaints and the effects of the Covid-19 pandemic, Amigo deemed
that it was not making enough money to pay all of its creditors. It
therefore proposed a scheme of arrangement to compromise its
liabilities and incorporated a special purpose vehicle, ALL Scheme
Limited (ALS), to promote the scheme.

This original scheme incorporated a mechanism, including a bar
date, to determine the claims of creditors who were seeking redress
against Amigo where it had granted loans to borrowers who could not
afford them. It also incorporated the claim of the Financial
Ombudsman Service (FOS) for case handling fees in relation to
complaints made by customers or their guarantors. Although this
scheme was approved by 95% of creditors attending and voting, it
was challenged by the FCA and the court ultimately refused to
sanction it.

Rejecting the scheme, Mr Justice Miles noted that he considered
that the redress creditors had not been provided with the necessary
information for them to properly consider the proposed scheme,
particularly in relation to the reasons why the redress creditors
were required to forgo the majority of their redress claims while
the shareholders of Amigo were not impacted. In addition, he did
not accept the directors' evidence that the failure of the scheme
would result in Amigo's immediate administration.

The alternative scheme proposals
Amigo is now proposing that redress creditors vote on two, new,
alternative schemes: the "New Business Scheme" and the "Wind Down
Scheme" (together, "the alternative schemes"). The New Business
Scheme incorporates a 'preferred solution' in which Amigo resumes
lending, and a "fallback solution" which will become effective if
the conditions of the preferred solution are not met. Under the
Wind Down Scheme, Amigo will not resume lending and will wind down
its business before being solvently liquidated.

Each of the alternative schemes provides for the creditor redress
claims to be compromised and a trust fund, the "scheme fund", to be
established from which redress creditors will receive a
distribution, provided that they have submitted claims before a
"bar date" to be adjudicated on.

Under the New Business Scheme, the following payments will be
made:

   * a first payment of GBP60 million into the scheme fund, no
later than five business days after the New Business Scheme becomes
effective;
   * a second payment of GBP37 million into the scheme fund no
later than nine months after the New Business Scheme becomes
effective;
   * GBP15 million from a recapitalisation of Amigo or such other
higher amount as the directors are able to obtain from investors at
the time of the rights issue; and
   * a "turnover amount", to be calculated by reference to the
amount of loan recoveries on Amigo's existing loan book in excess
of the sum of the first and second payments into the scheme fund
(GBP97 million), after making an allowance for a "liquidity
reserve" to pay Amigo's operating costs -- currently GBP8.4
million.

The New Business Scheme is conditional upon Amigo resuming lending
within nine months of its effective date and requires Amigo to
undertake a successful capital raise within 12 months, pursuant to
which current shareholders' holdings will be reduced to 5% of their
current holdings.  Should either of those conditions fail, or if
any of the first three payments noted above are not made, Amigo
will switch to the fallback solution.

Under the Wind Down Scheme, Amigo will collect its book as the
business is wound down, with an anticipated GBP95 million to be
available for redress creditors.

The High Court's decision
Lord Justice Snowden noted that the purpose of the convening
hearing was for the court to determine the class compositions, to
verify that the explanatory statement is in a satisfactory form and
to make directions for the holding of the scheme meetings. The
court may also consider whether the scheme -- or, in this case, the
schemes -- contains any obvious defects.

On the latter point, Lord Justice Snowden noted that Amigo had
taken steps to address Mr Justice Miles' concerns with the previous
scheme. Redress creditors' potential lack of financial or legal
advice was addressed by Amigo appointing an independent "customer
advocate" -- a solicitor with schemes of arrangement experience,
whose role is to liaise with customers and interested bodies -- to
review the scheme materials and report to the court. Amigo also
engaged a separate independent financial advisor to chair a
"customer committee" which was appointed to negotiate the terms of
the New Business Scheme with Amigo on behalf of the redress
creditors. The chair of this Committee also published online videos
to explain the alternative schemes to the broader redress creditor
group.

Mr Justice Miles' concerns around the shareholders not being
impacted under the previous scheme have also been addressed. Under
the New Business Scheme preferred solution, the condition to
conduct a capital raise of 19 new shares to each current share
addresses this concern as it will result in a dilution of current
shareholdings to 5%. Under the fallback solution or the Wind Down
Scheme, Amigo will not resume lending so shareholders will not
receive any benefit.

Amigo has also addressed the second criticism from Mr Justice
Miles. Lord Justice Snowden said he was satisfied that Amigo's
evidence showed that Amigo is insolvent and that Amigo will go into
administration if one of the schemes is not implemented.  The
relevant comparator to the alternative schemes is therefore the
administration of Amigo.  This point was also relevant in
considering the appropriate method of valuing the votes of existing
customer claims for the purpose of voting on the schemes with Lord
Justice Snowden considering at length points raised via the
customer advocate -- in particular from a well-known debt advisory
service, Debt Camel.  While understanding of the argument made by
Debt Camel, Lord Justice Snowden agreed with Amigo's vote valuation
proposal and noted that Amigo had chosen the correct comparator to
determine voting rights at the meetings, being administration.

It should also be noted that while the FCA has reserved its rights
in respect of the alternative schemes, it did not appear at the
convening hearing or otherwise make any objections.

In granting leave for ALS to hold the creditors' meetings to vote
on the alternative schemes, Lord Justice Snowden was satisfied that
the rights of customers, guarantors and the FOS in an
administration would be sufficiently the same to justify those
creditor types being placed in the one class.

Lord Justice Snowden also commended the drafting of the explanatory
statement which had been tailored to redress creditors by using
plain language and adopting flow charts and tables to assist the
reader; further noting that Amigo would make available a helpdesk,
accessible by phone and email, in the lead up to the meetings and
that the customer advocate would remain available to assist
customers.

In granting leave to convene the meetings, Lord Justice Snowden was
content for the two alternative schemes to be voted on at the same
meeting, noting that steps would need to be taken at the meeting to
ensure it was clear which of the alternative schemes was being
voted on each time.  Lord Justice Snowden was also satisfied that
it was appropriate for the meetings to be held virtually,
notwithstanding that the easing of Covid-19 restrictions meant that
the meetings could be held in person or by way of hybrid online and
in person meetings.  In reaching this conclusion, it was noted that
Amigo was an online business, it was more convenient for redress
creditors to attend online and the number of potential redress
creditors who could vote on the Schemes meant that a hybrid meeting
would be logistically complex.

Assuming that the redress creditors vote in favour of one or both
of the alternative schemes -- which seems likely given the outcome
of voting on the previous scheme -- the real test for Amigo will
come at the sanction hearing.  However, this convening hearing
decision is significant, as it demonstrates that the court will, in
appropriate circumstances, be prepared to allow creditors to vote
on two simultaneously proposed schemes of arrangement offering
alternative solutions for the relevant scheme company.

The decision is also significant in that it signals a potential
"new norm" in holding online creditors meetings, particularly where
the size of the creditor group could pose logistical challenges to
holding physical or hybrid meetings, perhaps even more so in
scenarios such as this where it can be evidenced that there is a
reasonable assumption that the relevant creditors have access to,
and familiarity with, the internet.

Amigo Loans -- https://www.amigoplc.com -- is the UK's largest
guarantor loan company.


ARDONAGH MIDCO 2: Fitch Affirms 'B-' LT IDR, Alters Outlook to Pos.
-------------------------------------------------------------------
Fitch Ratings has revised Ardonagh Midco 2 plc's Outlook to
Positive from Stable while affirming its Long-Term Issuer Default
Rating (IDR) at 'B-'. Fitch has also affirmed the ratings on its
senior PIK (payment-in-kind) toggle notes due 2027 at 'CCC' with a
Recovery Rating of 'RR6'.

The Positive Outlook reflects an improved operating risk profile
following increased geographic and customer diversification over
the last two years. Ardonagh is now more balanced across different
business segments. EBITDA has grown both organically and through
acquisitions and the company has extracted significant deal-related
synergies and made good progress in its cost-cutting programmes.

Ardonagh's Fitch-calculated funds from operation (FFO) gross
leverage remained above Fitch's rating sensitivity for an upgrade
to 'B' at end-2021. This does not include pro-forma EBITDA for the
acquisition of BGC Partners' insurance operations, which closed in
November 2021 but follows four previous years during which leverage
remained above the sensitivity. Fitch believes the company has the
financial flexibility to deleverage to below Fitch's sensitivities
within the next year but any future debt-funded acquisitions could
keep leverage above 7.5x. An upgrade to 'B' or above is possible
should the company demonstrate a commitment to maintaining leverage
sustainably below 7.5x.

KEY RATING DRIVERS

Leverage Thresholds Relaxed: Ardonagh has increased Fitch-defined
EBITDA to just below GBP300 million in 2021 from under GBP100
million in 2017 through acquisitions and organic growth. The
company has become a market-leading independent insurance
intermediary in the UK while also growing their presence in new
countries such as Ireland, Australia, US, Portugal and Brazil.
Fitch believes its operating risk profile has improved over the
last two years, which is reflected in a relaxed FFO gross leverage
threshold for an upgrade to 'B' to 7.5x from 7.0x.

M&A Increases Leverage: Its reported FFO gross leverage exceeded
Fitch's 7.5x sensitivity at end-2021 following the BGC Partners'
insurance operations acquisition in November 2021. FFO gross
leverage has been high for each of the last four years, reflecting
a series of largely debt-funded acquisitions, including 27 deals in
2021. The acquisition of BGC Partners' insurance operations was
large at over USD500 million, whose completion in November 2021
increased reported leverage. Adjusting for the deal would result in
pro-forma EBITDA in 2021 of around GBP360 million and leverage much
closer to Fitch's upgrade sensitivity, which supports the Positive
Outlook. Fitch believes the company's high EBITDA margins provide
it with the capacity to deleverage further though this could be
delayed by any debt-funded acquisitions.

Resilient Business Model: As brokers of typically non-discretionary
insurance products, companies such as Ardonagh are fairly well
positioned to withstand macroeconomic downturns. The strength in
its business model was further demonstrated during the pandemic
where it recorded organic revenue growth of 3% and 7% in 2020 and
2021, respectively. It has a well-diversified product portfolio
with the largest insurance class - casualty insurance -
representing only 14% of its gross written premiums in 2021. This
should help reduce the impact on Ardonagh of any future volatility
across individual insurance classes and the volumes of premiums
written globally.

EBITDA Margin Growth Expected: At end-2021 Ardonagh delivered over
GBP130 million cost savings and cost synergies to date. This
includes GBP25 million delivered in 2020 and GBP29 million in 2021.
The company has been a major consolidator in the fragmented UK, and
more recently in international, independent insurance brokerage
markets where cost synergy potential is high. The actions taken in
recent years have contributed to a significant growth in EBITDA
margin to over 30% by 2021 from around 20% in 2017. It has recently
guided a further GBP48 million of near-term cost savings, implying
further margin growth ahead.

Execution risk in M&A: While increasing scale is a key margin
growth driver in the insurance broking industry, Fitch believes
integration and cost-saving programmes may sometimes take longer
than expected, often demanding higher business transformation
spending and investments. Ardonagh has extracted good EBITDA growth
from previous acquisitions and cost-saving measures but
acquisitions of larger businesses such as BGC Partners' insurance
operations could come with higher integration risks. Funding
acquisitions through debt increases the importance of solid
execution of its cost-saving plans.

DERIVATION SUMMARY

Ardonagh has less scale in the UK than large international
insurance brokers. However, it has greater scale and a more diverse
product offering than other independent brokers Andromeda
Investissements SAS (B/Stable), and Diot-Siaci TopCo SAS
(B/Stable). While its expertise in niche, high-margin product lines
and its leading position among UK insurance brokers underpin a
sustainable business model, Ardonagh's higher financial risk from
higher leverage and execution risk of integrating acquisitions
constrain the rating.

KEY ASSUMPTIONS

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

-- Revenue to increase by around 35% in 2022, reflecting recent
    acquisitions including BGC Partners' insurance operations.
    This is followed by growth of around 6-8% per year through to
    2024;

-- Fitch-defined EBITDA margin to increase to 32.6% by 2024;

-- Capex to reduce to 1%-2% of sales per year in 2022-2024;

-- No dividend or shareholder remuneration between 2022 and 2024.

KEY RECOVERY ASSUMPTIONS

-- Fitch uses a going-concern approach for Ardonagh in Fitch's
    recovery analysis, assuming that it would be considered a
    going-concern (GC) in the event of a bankruptcy rather than be
    liquidated;

-- A 10% administrative claim;

-- Fitch's analysis assumes a GC EBITDA of around GBP300 million
    compared with its expected pro-forma - EBITDA of around GBP360
    million;

-- Fitch uses an enterprise value (EV) multiple of 5.5x to
    calculate a post-restructuring valuation;

-- These assumptions result in a recovery rate of 0% for the PIK
    notes within the 'RR6' range, resulting in the instrument
    rating being two notches below Ardonagh's IDR.

RATING SENSITIVITIES

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

-- Unchanged operating and regulatory conditions with sustained
    EBITDA margin stability. Positive FCF generation and a
    financial policy demonstrating a commitment to reducing FFO
    gross leverage sustainably below 7.5x or total debt with
    equity credit/operating EBITDA below 7.0x;

-- Successful execution of cost-saving programmes and realization
    of deal-related synergies;

-- FFO interest cover above 2x.

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

-- Consistently negative FCF and sustained use of revolving
    credit or other facilities to support liquidity;

-- Increasing competitive pressure or operational challenges
    resulting in lower EBITDA margins leading to FFO gross
    leverage being sustainably above 9.5x or total debt with
    equity credit/operating EBITDA above 9.0x;

-- FFO interest cover below 1.5x.

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: At end-2021 Ardonagh had GBP411.3 million of
available cash and is expected to generate positive FCF between
2021 and 2024. It has access to an undrawn senior secured revolving
credit facility (RCF) of GBP191.5 million. It also has access to an
undrawn portion on its B3 senior secured facilities of GBP164.3
million. Its unitranche and PIK toggle notes are bullet-structured
and mature in 2026 and 2027 respectively.

ISSUER PROFILE

Ardonagh is the largest diversified independent insurance
intermediary in the UK. Its strategy is to operate across four core
business segments including both B2C and B2B to capture maximum
commission and significant synergies across the insurance value
chain.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).

DEBT              RATING            RECOVERY    PRIOR
----              ------            --------    -----
Ardonagh Midco 2 plc

               LT IDR B- Affirmed               B-
Subordinated   LT CCC Affirmed        RR6       CCC

DERBY COUNTY FOOTBALL: Chris Kirchner Named Preferred Bidder
------------------------------------------------------------
Rohith Nair at Reuters reports that American businessman Chris
Kirchner has been named as the preferred bidder for second-tier
side Derby County, the English Championship club's administrators
said on April 6.

Mr. Kirchner, 34, said in October he wanted to take Derby out of
administration and was seeking approval from the English Football
League (EFL) to become owner of the club, Reuters relates.

"Following a rigorous and well-documented marketing process, the
joint administrators . . . have accepted an offer from Chris
Kirchner to acquire Derby County Football club out of
administration," Reuters quotes the administrators as saying in a
statement reported by British media.

Derby, managed by former Manchester United and England striker
Wayne Rooney, are 23rd in the standings after 40 games due to
points deductions imposed when they went into administration,
Reuters discloses.

               About Derby County Football Club

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

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


ELVIS UK: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable
--------------------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to quick service restaurateur Elvis UK Holdco and its 'B'
issue-level rating and '3' recovery rating to the group's proposed
EUR688 million of first-lien debt.

The stable outlook reflects that, despite operating performance
leading to S&P Global Ratings-adjusted leverage trending below 4.5x
in 2023, the company will not generate positive free operating cash
flow (FOCF) after lease payments over the next 24 months.

Although affected by a spike in energy prices at end-2021, RBI
managed to exhibit strong earnings for the year.

It surpassed its own budget by EUR7 million in terms of sales. This
performance is mainly attributable to Burger King Spain, which
exhibited more than 30% of absolute growth. Popeyes restaurants
remain a minimal contributor to the group's top line, driven by low
brand recognition and gradual openings, but S&P's expect the
contribution to increase over the next three years thanks to
additional funding for advertisement and an expanding network. At
end-2021, the group faced an 80% spike in energy costs. This
unexpected increase translated into a slightly weaker margin
profile, but absolute EBITDA remained in line with the budget, at
EUR104 million (management's calculation, pre-IFRS-16 EBITDA) due
to higher sales. As expected, RBI was FOCF negative in 2021, mainly
from high growth capital expenditure (capex) of about EUR80
million.

S&P said, "On the store network's strong earnings, the group is
accelerating its expansion plan, which will translate into negative
FOCF after leases payments in the next two years. This is contrary
to our initial anticipation of material positive FOCF by 2023.
While expanding the network, management has kept profitability
high, reducing the ramping-up period of newly opened restaurants
and having them profitable within six months. We deem this capacity
as best in class in the quick service restaurant (QSR) retailer
world. Although affected by inflation, partly counterbalanced by a
certain degree of pass-through to customers, we expect RBI to
exhibit an S&P Global Ratings-adjusted EBITDA margin of 21%-24%
over the next three years, only a slight decline compared with our
previous expectations. Taking into account low working capital
requirements and contained financial and rental expenses, the group
could generate EUR60 million-EUR70 million of FOCF after lease
payments if we were to deduct growth capex over the next two years
and assume a top-line growth based solely on the current store
network. Nevertheless, the company is planning to invest the cash
generated in the expansion of its network over the same period,
meaning about 50-60 openings per year against the 40 we had
anticipated in our initial base-case scenario. This translates in
our estimation of EUR75 million-EUR85 million net growth capex per
year, which combined with maintenance ones means negative FOCF over
the next two years.

"Acquisitions are likely to weigh on the group's deleveraging path,
but we still expect leverage to be contained below 5.0x.Since the
end of 2021, RBI has accelerated its acquisition plan. The group
acquired 19 franchisees financed through a EUR30 million drawdown
on the RCF, leaving EUR120 million available. We previously
expected six-to-eight acquisitions per year. Also, in February
2022, the group submitted a nonbinding offer to Ibersol to acquire
its Burger King network for an enterprise value estimated at EUR250
million. This includes 160 restaurants, of which 120 are in
Portugal, where RBI has limited exposure, and the rest in Spain.
Ibersol is a multi-brand group with most of its operations in the
Iberian Peninsula. The group-operated brands include Burger King,
KFC, Pasta caffe, RBIS, and Pizza Hut. Ibersol is the franchisee
with the highest number of Burger King restaurants in the Iberian
Peninsula after RBI, the rest of the network being fragmented among
smaller owners. The financing structure has not been disclosed nor
has specific operating performance of the Burger King network,
because the group only discloses consolidated figures.
Nevertheless, we expect the financing structure to comply with the
shareholder agreement, with Burger King Europe specifying a maximum
financial leverage ratio of 4.0x in the normal course of operations
and 4.5x in case of acquisitions, and with the group's leverage cap
set in its term loan B documentation. We therefore believe that RBI
will be releveraged at 4.5x, which would translate into an S&P
Global Ratings-adjusted leverage of 4.5x-5.0x, delaying our
deleveraging expectations. We have not integrated this acquisition
in our base-case scenario yet because its completion isn't certain.
While this acquisition should not materially deteriorate our
calculated credit metrics, it nevertheless highlights a more
aggressive financial policy than what we had anticipated and
heightens the execution risk associated with the group's very
ambitious expansion plan.

"The stable outlook reflects that, despite high like-for-like
revenue growth and strong S&P Global Ratings-adjusted EBITDA margin
at 22%-23%, S&P Global Ratings-adjusted leverage should remain
close to 5x in 2022, with continuing negative FOCF after lease
payments throughout the next 24 months, driven by a more ambitious
network expansion than originally anticipated, both through
acquisitions and store openings."

S&P could lower the rating over the next 12 months if RBI's
operating performance and credit metrics deteriorated. This could
occur if the group's expansion plan is more costly than anticipated
or RBI were to undertake other large debt-funded acquisitions, such
that:

-- S&P Global Ratings-adjusted EBITDA margin declines to about
20%.

-- S&P Global Ratings-adjusted leverage ratio crosses 5x.

-- The group's negative FOCF becomes sizable such that liquidity
weakens.

S&P could raise the rating over the next 12 months if RBI executes
its expansion plan ahead of its expectations, translating into S&P
Global Ratings-adjusted leverage declining sustainably to about 4x
and free cash flow after leases remaining positive in the next
couple of years. Rating upside would also be contingent on the
group's financial policy being consistent with sustaining the
improved credit metrics.

ESG credit indicators: E-2, S-2, G-3


LERNEN BONDCO: S&P Affirms 'CCC+' Long-Term Issuer Credit Rating
----------------------------------------------------------------
S&P Global Ratings affirmed its 'CCC+' long-term issuer credit and
issue ratings on K-12 school operator Lernen Bondco (Cognita).
S&P's recovery rating of '3' (indicating 50%-70% recovery; rounded
estimate: 65%) on Cognita debt (including the new EUR180 million
tap) is unchanged.

The stable outlook indicates that S&P views the group's liquidity
as adequate for its operating needs. Its support from its sponsor
is solid and the sizable investments it has made, combined with its
ability to push through fee increases, should result in solid
revenue and earnings growth over the next 12 months.

Given the EUR180 million add-on to the term loan B, Cognita's
leverage will now reduce more slowly in 2022 than S&P's previously
anticipated.

The proceeds of the add-on facility will effectively pay for the
initial purchase consideration of the four schools that the group
has acquired since the beginning of the current financial year.
These schools are based in United Arab Emirates (UAE), Spain,
Mexico, and Chile and their acquisition supports the group's
strategy of improving its geographic diversity. That said, the
acquisitions are fully debt-funded and were negotiated at an EBITDA
multiple of about 12x-15x, with an initial cash outlay of about
GBP150 million and deferred consideration of about GBP80 million in
the medium term. S&P said, "Including these transactions, we
calculate that the group leverage for 2022 will remain elevated at
about 10.5x (compared with 11.5x in 2021), well above our previous
expectation of 9.0x. We consider Cognita's decision to fully
debt-fund its acquisitions as aggressive."

The transaction replenishes Cognita's liquidity buffers, thus
reducing the probability of a near-term default. The completion of
the transaction gives Cognita access to GBP235 million of
liquidity, comprising GBP135 million in cash and GBP100 million in
a revolving credit facility (RCF). S&P's forecast that cash flow
from operating activities after deducting cash interest, cash
taxes, rental expenses, and maintenance capital expenditure
(maintenance capex) will be positive in FY2022. This
growth-capex-adjusted free cash flow was negative GBP3 million in
FY2021 and negative GBP38 million in FY2020. Cognita plans to
invest GBP150 million of growth capex over the next three years and
its current liquidity provides a sufficient buffer to complete
these projects.

S&P said, "In our view, Cognita's sponsor, Jacobs Holding, is
committed to the business and will continue to support the business
with cash injections for any liquidity needs or to support a
materially large acquisition. That said, the sponsor is comfortable
maintaining high leverage at Cognita and so is unlikely to bring
fresh equity to help reduce leverage in the capital structure. The
sponsor has demonstrated its commitment to the business by
investing additional equity of GBP250 million over the past two
years, in addition to its GBP1.3 billion equity contribution when
it initially acquired Cognita in October 2018. Jacobs Holding has
held this investment since 2018. We anticipate that it will
steadily grow the business over the next five years. Its likely
exit strategy will be to list the equity of the business.

"Cognita's profitability continues to lag its peers. As the impact
of COVID-19 discounts receded, Cognita's EBITDA margins improved to
20.3% in 2021 from 18.5% in 2020. We forecast that they will exceed
23% in 2022. Nevertheless, Cognita's margins remain well below
those of its closest peers: Bach Finance (Nord Anglia) at about 34%
and Inspired Education at about 30%. The factors that contribute to
the difference include lower margins in Europe, particularly in
U.K. schools (40 of its 89 schools) due to the competitive pricing
dynamic, relatively higher staff cost profile, and the initial
loss-making profile of some of its recent greenfield projects.

"The stable outlook indicates that we consider the group's
liquidity adequate for its operating needs and its support from its
sponsor solid. The sizable investments it has made, combined with
its ability to push through fees increases, should result in solid
revenue and earnings growth over the next 12 months."

Despite its high leverage, S&P could upgrade Cognita if:

-- It maintains a steady improvement in its operating performance,
demonstrated by increasing enrolment levels (particularly in the
schools for expatriate children), higher capacity utilization, and
margin strengthening to above 24%-25%.

-- Its cash flow improves, indicating potential to reduce leverage
as the group's scale increases. For example, it can achieve and
maintain growth-capex adjusted FOCF to debt of above 2%-5%.

-- It maintains its track record of proactively managing its
liquidity profile at an adequate level.

-- Upside potential could also arise if the company was to
undertake material equity-funded acquisitions or raise fresh equity
to repay debt and improve the sustainability of its capital
structure, giving it a materially lower leverage profile.

S&P said, "We could lower the rating on Cognita if we expected the
company to undertake a debt restructuring, interest deferral,
distressed debt exchange, or default within the next 12 months. We
could also lower the rating if shareholders appeared reluctant to
bring in fresh equity when necessary or liquidity is weakened, such
that we expect a material shortfall to meet its upcoming needs or
we expect a covenant breach."

S&P could also downgrade Cognita if it assessed the group's
business profile as impaired because of:

-- A permanent drop in the enrolment levels in key markets like
Singapore;

-- Low uptick in capacity utilization with its new development
projects (particularly Dubai); or

-- A failure to improve operating margins.

ESG credit indicators: E-2, S-2, G-3


MECHANICAL FACILITIES: Cash Flow Pressures Prompt Administration
----------------------------------------------------------------
Grant Prior at Construction Enquirer reports that administrators
are now in charge of M&E specialist Mechanical Facilities Services
Limited and have made all but a handful of its 75 staff redundant.

Administrator Interpath Advisory said the company came under
increasing cashflow pressure in the weeks prior to its appointment
as a result of a dispute on a large contract, Construction Enquirer
relates.

According to Construction Enquirer, as no resolution could be
reached imminently, the directors made the difficult decision to
cease to trade and place the company into administration,
Construction Enquirer.

MechFS had 75 employees upon appointment, of which six have been
retained to assist the administrators with the wind-down of the
business, Construction Enquirer discloses.

MechFS was founded in 2008 and operated as a mechanical and
electrical contractor offering bespoke engineering solutions
nationwide and through its sister companies in Ireland and
Germany.


NMCN: Former Employees Files Legal Action Over Redundancy Process
-----------------------------------------------------------------
Joshua Stein at Construction News reports that former employees of
the collapsed utilities specialist NMCN have taken the business to
tribunal over the handling of their redundancies.

According to Construction News, the 26 employees of the GBP400
million-turnover firm, which appointed administrators in October,
say the company failed to consult with them about the job losses.
If they succeed at the employment tribunal, they could access up to
GBP4,352 each via the government's Insolvency Service, Construction
News states.

Law firm Simpson Millar, which is representing the former staff,
first announced days after NMCN's collapse that it was preparing a
legal case, Construction News notes.

Simpson Millar employment lawyer Anita North said the employees
were "taken completely by surprise" when they were made redundant
last year, Construction News relates.

"Twenty-six ex-employees later instructed us to investigate the
claims that NMCN had failed to properly consult over the job
losses, and they have now officially taken their claim to an
employment tribunal to be heard," she added. "We are now awaiting a
date for a preliminary hearing to take place."

The individuals were all working for NMCN's building business, for
which administrators at Grant Thornton failed to find a buyer,
leading to the loss of 80 jobs, Construction News discloses.  The
administrators successfully sold the company's telecoms business
and most of its plant and machinery to Svella, while Galliford Try
bought its water division and Keltbray Highways acquired parts of
its infrastructure operations, Construction News recounts.

Construction News revealed in October that nearly 2,400 unsecured
creditors would lose more than GBP60 million due to NMCN going
under.  In October, the Financial Reporting Council began its
investigation into NMCN's auditor, BDO, Construction News relays.

NMCN was one of 23 companies that went into administration in
October -- marking the highest monthly toll of business failures in
2021 and in the wake of the first coronavirus lockdown in March
2020, Construction News notes.

Restructuring specialist Blair Nimmo told Construction News at the
time that the sector was facing a "perfect storm" of rising
material costs, huge wage inflation, HGV-driver shortages and
global shipping issues.


TM LEWIN: Strikes Acquisition Deal with PETRA Group
---------------------------------------------------
Mark Kleinman at Sky News reports that the main lender to TM Lewin
has struck a deal to buy the century-old shirtmaker after it
collapsed into insolvency for the second time in less than two
years.

Sky News has learnt that an investment vehicle owned by PETRA Group
has reached agreement with TM Lewin's administrators, Interpath
Advisory, to acquire the prominent fashion brand.

A deal could be announced before the weekend, according to one
source, Sky News notes.

PETRA's swoop to acquire the business comes less than a month since
it fell into administration, ending a disastrous spell under the
ownership of Torque Brands, a company set up by Simba Sleep founder
James Cox, Sky News relates.

The company, which claims to have sold more than 70 million shirts
during its 124-year history, axed all 66 of its physical shops as
part of its last skirmish with insolvency, resulting in the loss of
hundreds of jobs, Sky News discloses.

It is now thought to employ fewer than 100 people, Sky News
states.

According to Sky News, PETRA is said to be interested in reviving
the brand's high street presence despite the shift to home-based
working during the pandemic.


WARRENS BAKERY: Calls CVA a Success After Return to Profitability
-----------------------------------------------------------------
Amy North at British Baker reports that Warrens Bakery has called
its Company Voluntary Agreement (CVA) a success after the business
returned to profit in 2021.

According to British Baker, newly filed accounts on Companies House
for the full year to June 30, 2021, show the firm's operating
profit to be GBP471,000 -- a significant improvement on the GBP2.7
million loss the year prior.

Turnover was down year on year from GBP12.8 million to GBP9.6
million, British Baker notes.  However, it said this is due to the
closure of 18 loss-making shops as well as the closure of
loss-making production facilities with their related wholesale
sales, British Baker notes.  Hospital sites also continued to be
impacted due to the pandemic, British Baker discloses.

"Given the pandemic's impact on the business and the restrictions
to trade, further action was taken to negate the shortfall in trade
over the traditionally buoyant summer 2020 period," British Baker
quotes the company as saying.  "This included a series of cost
saving measures as well as the company seeking variations of the
Company Voluntary Arrangement which were approved by creditors in
July 2020."

The business first agreed a CVA -- a process which enables a
company to negotiate the repayment of debt rather than filing for
liquidation or insolvency -- with its suppliers and landlords in
December 2019, British Baker recounts.  It followed the
announcement of a major restructure which included shop and factory
closures as well as redundancies.

In July 2020, Warrens requested creditor approval to maintain
payments of GBP5,000 a month for 12 months versus the originally
proposed GBP24,000, British Baker relays.  It was amended again in
February 2022 given the business' improved performance with a final
payment of GBP500,000 made in March 2022, British Baker discloses.


A final dividend payment to creditors is expected in April 2022
after which the CVA will be discharged, British Baker states.  This
will result in a write back to profit of around GBP1.8 million,
British Baker notes.




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

Copyright 2022.  All rights reserved.  ISSN 1529-2754.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.

Information contained herein is obtained from sources believed to
be reliable, but is not guaranteed.

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delivered via e-mail.  Additional e-mail subscriptions for
members of the same firm for the term of the initial subscription
or balance thereof are US$25 each.  For subscription information,
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