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ISSUER IN-DEPTH
22 JULY 2015

Commonwealth of Puerto Rico

Frequently Asked Questions About


Puerto Rico's Fiscal and Debt Crisis
As Puerto Rico (Caa3 negative) and its related issuers face the mounting probability of
default, there are key questions about future recovery rates for bondholders, the likelihood of
Puerto Rico averting a default and what its restructuring might look like. This report answers:

ANALYST CONTACTS
Ted Hampton
VP-Sr Credit Officer
ted.hampton@moodys.com

212-553-2741

Bondholder Recovery: What do your ratings on various Puerto Rico securities imply for
bondholders?

Emily Raimes
VP-Sr Credit Officer
emily.raimes@moodys.com

212-553-7203

Timothy Blake
212-553-4524
MD-Public Finance
timothy.blake@moodys.com

Missed Trustee Payment: How do this months disclosures that Puerto Rico failed to
make a scheduled trustee payment on one type of debt and that it would seek to buy
back another type affect your view?

Thomas Aaron
312-706-9967
AVP-Analyst
thomas.aaron@moodys.com

Economic Growth and Revenue: Can Puerto Ricos economy recover fast enough to
generate sufficient government revenue to pay debt service?

Brandan Holmes
212-553-6897
VP-Senior Analyst
brandan.holmes@moodys.com

Pension Risk: When do you expect Puerto Ricos pension fund assets to be fully
depleted, and how will that affect expenditures?

Federal Role: Will the US federal government bail out Puerto Rico?

212-553-1911

Comparison to Sovereign Restructurings: What makes Puerto Rico similar to, or


different from, a sovereign nation restructuring its debt?

Anne Van Praagh


212-553-3744
MD-Sovereign Risk
anne.vanpraagh@moodys.com

Bond Insurance: Bond insurers loaned money to the Puerto Rico Electric Power
Authority to prevent default. What are the implications of that decision for other
commonwealth obligations?

Elena H Duggar
Senior Vice President
elena.duggar@moodys.com

MOODY'S INVESTORS SERVICE

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Q: What do your ratings on various Puerto Rico securities imply for bondholder recovery?

A: Our ratings are based not only on the probability of default but also on the loss given default. Combining these two figures produces
the expected loss that our ratings express. Looked at another way, our ratings also convey our expectations for bondholder recoveries
(see Exhibit 1). In the case of Puerto Rico, we believe that the probability of default is approaching 100%, and that losses given default
are substantial. At present, we assume that the commonwealth will seek to restructure its debt in a consolidated fashion, affecting all
bondholders to varying degrees.
Exhibit 1

Puerto Rico and related ratings fall within Caa3 and Ca catagories
Security

Rating

General obligation (and


Caa3/Neg
commonwealth-guaranteed)
COFINA Senior
Caa3/Neg
COFINA Junior
Ca/Neg
PRIDCO General Purpose Revenue
Caa3/Neg
Bonds
Aqueduct and Sewer Authority
Caa3/Neg
(PRASA)
Municipal Finance Authority (MFA)
Ca/Neg
Puerto Rico Electric Power Authority Caa3/Neg
(PREPA)
UPR System Revenue Bonds
Ca/Neg
UPR Educational Facilities Revenue
Ca/Neg
Bonds
Appropriation-backed debt
Ca/Neg
Government Development Bank notesCa/Neg
Highways and Transportation
Ca/Neg
Authority (PRHTA)
PRHTA Subordinate Transportation Ca/Neg
Revenue Bonds
Infrastructure Finance Authority
Ca
(PRIFA)
Pension Funding Bonds (ERS)
Ca/Neg
Convention Center District Authority Ca/Neg
Hotel Occupancy Tax Revenue Bonds
Total

Outstanding

Expected Recovery Rate

$18,566,000,000

65% to 80%

$6,244,000,000
$9,000,000,000
$176,895,000

65% to 80%
35% to 65%
65% to 80%

$3,852,450,000

65% to 80%

$781,220,000
$9,054,243,000

35% to 65%
65% to 80%

$470,775,000
$68,700,000

35% to 65%
35% to 65%

$1,165,534,000
$5,137,257,000
$4,418,535,000

35% to 65%
35% to 65%
35% to 65%

$298,465,000

35% to 65%

$1,889,303,000

35% to 65%

$2,948,000,000
$408,530,000

35% to 65%
35% to 65%

$64,479,907,000

Sources: Government Development Bank, Moodys Investors Service data.

As indicated by our ratings and shown in Exhibit 1, we believe that bondholder recoveries will be lowest on securities lacking
explicit contractual or other legal protections. These securities consist of those rated Ca, including notes issued by the Government
Development Bank for Puerto Rico and the commonwealths subject-to-appropriation debt. We lowered the ratings on most of these
securities to Ca from ratings in the Caa range on May 21.
On July 1, after Governor Alejandro Garca Padilla declared that Puerto Rico could not pay its debt, we affirmed ratings on the Carated bonds and also downgraded several other securities to that level. Legally protected securities consist primarily of general
obligation and guaranteed debt, of which more than $18 billion is outstanding. Constitutional provisions, such as Article VI, Section
8, which gives GO bondholders a first claim on the governments available resources, support these bonds. However, we downgraded
even those securities on July 1 for two reasons. First, it will be hard for the commonwealth to achieve significant fiscal relief through
debt restructuring if it completely excludes GO and guaranteed bonds. The GO and guaranteed debt category accounted for onethird of the commonwealths net tax-supported debt in our 2015 Debt Medians report , and it also accounted for 43% of its annual
debt service burden, as of fiscal 2014. Second, the commonwealth had signaled that GO bonds would not be immune from its debt
restructuring, by suspending a legal requirement to make monthly set-asides for GO bond debt service.
This publication does not announce a credit rating action. For any credit ratings referenced in this publication, please see the ratings tab on the issuer/entity page on
www.moodys.com for the most updated credit rating action information and rating history.

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If the commonwealth cannot achieve a negotiated settlement, GO bondholders have the right to sue the commonwealth for a clawback of revenues allocated to other bonds in order to make GO payments, under Article VI Section 2 of the constitution. As shown in
Exhibit 1, we still anticipate better recovery rates for GO and guaranteed bonds, as well as for the bonds we believe will be protected
from the claw-back mechanism. These include bonds issued by the Puerto Rico Aqueduct and Sewer Authority (PRASA) and the Sales
Tax Financing Corporation (COFINA) senior-lien revenue bonds. The claw-back mechanism, touted for many years as an immutable
bondholder protection, has never been implemented. In the negotiated restructuring that Puerto Rico is seeking, we believe that the
threat of activating the claw-back mechanism will compel the government to offer somewhat higher remuneration to holders of GO
and guaranteed bonds, at the expense of investors with securities vulnerable to the claw-back. This will tend to drive recovery rates
lower for holders of subject-to-appropriation debt, GDB senior notes and other instruments that lack the strongest legal protections.
Our working estimates are based on reductions in principal and interest payments of about 40% annually through 2023, factoring in
cuts of about 25% for Caa3-rated bonds and 55% for Ca-rated bonds. Implied recovery rates are 75% and 45% are in the middle of the
respective Caa3 and Ca ranges. Our estimate, covering fiscal years 2016 through 2023, is based on a scenario in which the government
chooses to reduce debt service payments to avoid operating deficits. It assumes flat tax revenue growth, steady levels of spending on
general government services, and the need to cash-fund retirement benefits for the commonwealths two largest pensions starting in
fiscal 2019. Actual losses will of course reflect factors that are difficult to assess at this point, such as the potential for a protracted legal
process in which bondholders with differing agendas block implementation of a broad agreement.

Q: How is your view affected by Puerto Rico's failure to make a scheduled trustee payment and by the
GDB's debt repurchase efforts?

A: On July 15, Puerto Ricos Public Finance Corporation (PFC) disclosed that it had failed to make a $93.7 million scheduled transfer
that day to the bond trustee for payment on its approximately $930 million of outstanding debt. On July 9, the Government
Development Bank for Puerto Rico (GDB, Ca negative) said it would seek to purchase its outstanding notes at prices expected to be
materially less than par. Both of these disclosures were in line with our expectations. We downgraded both the PFC and GDB bonds,
among others, to Ca negative on May 21. This action was driven by our conclusion that the central government and GDB, its fiscal
agent, would pursue cash-conservation tactics that would lead to default and investor losses, particularly for securities not protected
by the strongest revenue pledges or constitutional provisions. This debt category, we believe, includes both the PFC and GDB securities.
PFCs bonds require annual legislative appropriation for payment, and bondholders have limited remedies if the legislature fails to
take action. While the GDB has played a central role in Puerto Ricos financial activities for many years, its securities lack specific legal
safeguards for bondholders, such as the constitutional provisions that support the commonwealths GO bonds.
At this point, we do not believe a default has yet occurred on either PFC or GDB securities, although both of the disclosures
demonstrate the high likelihood and increasing imminence of default and bondholder losses. For the GDB securities, it is probable that
any bond buybacks would represent distressed exchanges, which we view as a form of default.1 More immediately, Puerto Rico faces
a payment default on the PFC's subject-to-appropriation bonds because of legislative inaction. The PFC's scheduled August 1 payment
to bondholders is $58 million. The PFCs obligation to transfer funds to the trustee on July 15 was contingent upon the passage of
appropriations that did not occur. As is typical of subject-to-appropriation bonds, legislative inaction alone does not constitute a
default. Corrective action from the legislature, which currently is not in session, appears unlikely before the August 1 payment date.

Q: Can Puerto Rico recover fast enough to generate enough government revenue to support its debt?

A: Puerto Rico lacks an obvious engine of recovery, and some of the commonwealths primary economic sectors continue to contract.
Employment in the pharmaceutical and medicinal manufacturing sector is estimated to have plunged more than 50% in the nine
years ending in 2014 (see Exhibit 2). One bright spot in the economy, tourism, accounts for comparatively small portions of both
employment and economic output, and it also faces growing regional competition.

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COMMONWEALTH OF PUERTO RICO: FREQUENTLY ASKED QUESTIONS ABOUT PUERTO RICO'S FISCAL AND DEBT CRISIS

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Exhibit 2

Pharmaceutical manufacturing jobs have declined

Source: US Bureau of Labor Statistics

Given the weak job supply and the ease of migration to the mainland US, it is not surprising that outmigration has eroded Puerto
Ricos economy for 17 consecutive years (see Exhibit 3). Labor force participation, at 40%, is a fraction of the nations 63%. Despite
the chronic population losses and Puerto Ricos low labor-force participation, the percentage of workers who are unemployed is 12.6%,
more than twice the nations 5.3%.
Exhibit 3

Population has steadily declined as Puerto Ricans move to the mainland

Source: US Census Bureau

Puerto Ricos economic output will keep declining or stagnate in coming years, Moodys Analytics projects. The commonwealths
nominal growth rate is projected at 0.4% this year and 0.6% in 2016. In order to sustain its existing debt load without cuts to non-debt
expenditures, we believe that the commonwealth would need sufficient economic expansion to generate tax revenue growth of almost
7% in 2017 and about 2.5% a year thereafter. Currently, debt service to gross national product is 6.2%, relatively low by international
standards. The debt service burden is nevertheless onerous given the commonwealths lack of growth, accounting for about 14% of the
consolidated budget this fiscal year. Assuming no resurgence of economic and revenue growth, we estimate that the commonwealth
could support approximately 60% to 65% of its net tax-supported debt (excluding the Puerto Rico Electric Power Authority).

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Q: When will Puerto Ricos pension assets be depleted, and how will that affect expenditures?

A: Both the Teachers Retirement System (TRS) and Employees Retirement System (ERS) may fully deplete their assets in 2020, based
on our analysis. This timeline is closely aligned with that of the plan actuaries and assumes no further reforms for either plan. Plan
actuaries for TRS have also noted that because of the illiquid nature of plan assets, the ability of the pension fund to make benefit
payments could end even sooner.
Adverse investment performance or practices that undermine funding would obviously accelerate the pace of asset depletion. For
example, the government is evaluating the use of pension assets for liquidity advances to its Treasury Department, with the Treasury
subsequently assuming responsibility for benefit payments. Currently, the pension funds reimburse the Treasury from plan assets after
it makes benefit payments to retirees. Pursuing this strategy could negatively affect the funds' ability to seek investment returns and
could accelerate asset depletion.
Once the plans assets are exhausted, Puerto Rico would switch to paying retiree benefits directly using only general operating
revenues, which would greatly add to ongoing expenses. Estimated 2021 benefit costs for TRS and ERS participants combined are $2.3
billion, or about 25% of general fund revenues that year, assuming no revenue growth until then.
The commonwealth so far has not mentioned reductions to employee pension liabilities in proposed debt-restructuring efforts. This
approach is consistent with US Chapter 9 bankruptcies in recent years, where pension liabilities have mostly been treated favorably
relative to bondholders, and have even been completely unimpaired in several cases.
Should it seek to reduce pensions for expenditure relief, Puerto Rico faces legal uncertainty. The government's legal capacity to
diminish benefits has been both affirmed and put in question by apparently conflicting rulings from the commonwealths Supreme
Court in recent years. In April 2014, the court struck down Act 160, a 2013 reform intended to maintain the solvency of the TRS and
Judicial Retirement System by increasing minimum retirement ages and employee contribution requirements, and by implementing
a defined contribution plan for future benefit accruals. Conversely, the court in 2013 had approved the constitutionality of Act 3, a
similar package of reforms for ERS, indicating that, in keeping with prior rulings, the court would allow reasonable reforms to maintain
pension plan solvency. The court in 1987 had ruled that although public pension plan participants have contractual and vested rights to
their benefits, the legislature can allow for reasonable changes in benefits to promote a plans actuarial solvency.

Q: Will the US federal government bail out Puerto Rico?

A: Any scenario resembling an outright bailout is highly improbable. Unlike in many other countries, the federal government does not
provide states or local governments with extraordinary funds to avert defaults on their debt, in part because doing so would induce
other governments to take on unsustainable amounts of debt or engage in reckless fiscal practices. Our ratings assume that not only
will there be no federal payment of debt service, but that the federal governments efforts on Puerto Ricos behalf will have only
marginal near-term effects.
The commonwealth is seeking several specific measures from the federal government, such as improved Medicare payment terms
and the ability to use the US Bankruptcy Code. The proposed bankruptcy measure (H.R. 870) would revise a portion of the bankruptcy
code that, since 1984, has specifically excluded Puerto Rico from Chapter 9, which applies to public-sector reorganizations. Puerto
Ricos non-voting member of Congress proposed H.R. 870 (also known as the Puerto Rico Chapter 9 Uniformity Act of 2015), and
it has drawn support from prominent Democrats, but it still faces significant challenges. Even if Congress did reach a consensus on
opening bankruptcy courts to the commonwealth, we would expect that a large portion of Puerto Ricos debt would not be eligible for
bankruptcy restructuring. States themselves cannot file for bankruptcy protection under Chapter 9. Since Puerto Rico is treated as a
state under the Bankruptcy Code, only its authorized municipalities (or public corporations) that can demonstrate insolvency would be
eligible for protection if H.R. 870 were enacted.
A bankruptcy filing might provide for a more orderly process with comparatively better recovery rates for a subset of bondholders,
excluding direct debt of the central government as well as public corporations unable to show insolvency. Such a partial restructuring
might not be worth the effort, in view of Puerto Ricos urgent pressures. Since Chapter 9 is unlikely to be a viable way to achieve a
consolidated restructuring of all the commonwealths debt, bankruptcy authorization would not be sufficient, by itself, to manage
Puerto Rico's current pressures.

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Congress could also seek to impose a fiscal and economic control board, as it did for the District of Columbia in 1995, after a
succession of operating deficits, cash shortfalls and identification of widespread management problems. The political hurdles to
imposing a similar control board on Puerto Rico are high, given the broad powers with which such a control board would be endowed.
Tangible benefits from implementing a control board would take time, and no legislation has yet been advanced to form a control
board. Congress has explicit oversight of the nations capital pursuant to Article I Section 8 of the US Constitution, which made
Congress's imposition of a control board more straightforward and, arguably, imperative. Other support from Congress could come
in the form of humanitarian assistance, if economic conditions deteriorate dramatically, or through amendments to the Jones Act of
1920, which imposes high shipping costs on Puerto Rico.

Q: What makes Puerto Rico similar to, or different from, a sovereign nation restructuring its debt?

A: Puerto Rico is in the unusual position of being similar to a US state, but lacking a state's full legal rights. It uses the US currency and
receives various forms of federal support, but it is self-governing, lacks real representation in Congress and, in some legal respects, is
treated as a foreign jurisdiction under US law. Because of the US government's reluctance to intervene financially in any state or local
debt crises, we believe Puerto Rico's restructuring will play out largely along the lines of sovereign debt crises.
However, unlike Greece (Caa3 on review for downgrade), Puerto Rico cannot turn to a lender of last resort, such as the International
Monetary Fund or other supranational structures for oversight or financing. Another key difference between Puerto Rico and a
sovereign nation restructuring is the commonwealth's complex array of security types with varying contractual provisions and seniority
levels. National governments typically have fewer debt types, with differences relating to the treatment of domestic, external, official
sector and private sector creditors, rather than seniority of claim. The multiplicity of Puerto Rico's securities may complicate its efforts
to reach a broad restructuring agreement with all creditors, even after a lengthy negotiation period.
Another difference is that most sovereign bonds include collective action clauses, which typically allow consent from 75% of
bondholders to bind all others to a restructuring plan. Puerto Ricos contractual provisions lack collective action clauses, which may
further complicate matters. Additionally, some Puerto Rico bonds provide for New York legal jurisdiction and others for Puerto Rico
courts. Before the restructuring process can begin, these jurisdictional issues may need to be sorted out. Some sovereigns have dealt
with such parallel legal structures, though it can prolong recovery proceedings (see Exhibit 4).
Exhibit 4

Legal Features of Rated Defaults since 2000


Country

Initial Default Date

Distressed Exchange Date

Governing Law

Creditor Structure

Argentina
Argentina
Moldova
Nicaragua
Nicaragua
Dominican Republic
Belize
Ecuador
Jamaica

Nov-01
Nov-01
Jun-02
Jul-03
Jul-03
May-05
Dec-06
Dec-08
Feb-10

Nov-01
Feb-05
Oct-02
Jul-03
Jun-08
May-05
Feb-07
May-09
Feb-10

Dispersed
Dispersed
Concentrated
Concentrated
Concentrated

Greece

Mar-12

Mar-12

Belize
Jamaica

Sep-12
Feb-13

Mar-13
Feb-13

Local Law
Eight Governing Laws
English Law
Local Law
Local Law
New York Law
New York Law
New York Law
Local Law
Local law and
some foreign law
New York Law
Local Law

Concentrated
Concentrated
Dispersed
Concentrated
Concentrated

Sources: Moodys Investors Service, Sturzenegger and Zettelmeyer (2005), Diaz-Cassou, Erce-Dominguez and Vazquez-Zamora (2008), and Andritzky (2006). Sovereign

Series: The Aftermath of Sovereign Defaults, October 2013

Defaults

Still another difference between Puerto Rico's situation and sovereign restructuring is the commonwealth's diverse investor base.
National government debt tends to be held by a few funds and domestic banks with large stakes, which makes negotiating a
restructuring accord easier. Puerto Ricos securities, by contrast, are widely dispersed among numerous kinds of investors: individuals,
mutual funds and speculative holders such as hedge funds. For a given Puerto Rico bondholder, the degree of concentration in Puerto

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Rico debt tends to be small. This further suggests that the central government faces a daunting challenge to forge consensus with a
broad range of investors.
The criteria for an eventual restoration of Puerto Rico's market access for new bond offerings will also likely differ from sovereigns
that re-enter the market following default. While many national governments in restructuring cases face challenges from devaluation
of their currencies, Puerto Rico's main hurdle will likely be the ability to show that its economy has transcended the structural
impediments to growth that have long weighed on it since 2006.

Q: Bond insurers loaned money to the Puerto Rico Electric Power Authority (PREPA, Caa3 negative) to prevent
default. What are the implications of that decision for other commonwealth obligations?
A: The $128 million of bridge loans that insurers provided allowed PREPA to make its July 1 debt service payment in full, avoiding
a default. Delaying an actual default or debt restructuring, and establishment of the ultimate loss severity, helps the guarantors in
several ways .

First, a default would have disrupted ongoing negotiation between PREPA and its creditors. Continuing the dialogue, outside of a
default situation, may improve recovery prospects. The guarantors support for PREPAs July principal payment was the first concrete
and material evidence that the guarantors and PREPA are having ongoing constructive dialogue to resolve PREPAs operational and
capital structure challenges, increasing the likelihood of higher recoveries in the event of a default. It also underscored the guarantors
extensive workout expertise and the variety of tools that they can use to contribute to the debt restructuring process. These tools
include not only the ability to provide financing, but also the ability to insure bonds to assist with post-restructuring market access. The
insurers have a contractual basis to assert control rights in an event of default, and their long time horizons allow a patient approach in
working towards an optimal solution.
Second, having more time until a restructuring or default works in guarantors favor. As time passes, and given limited new business
activity, guarantors insured portfolios amortize and premium revenues are recognized, contributing to improved regulatory and
economic capital profiles, dampening the effect of a Puerto Rico loss. Also, under GAAP and statutory accounting rules, guarantors
record losses based on a probability-weighted range of outcomes. This means that the actual reported losses reflect guarantors
perception of the range of possible losses and is not simply driven by a default or the insurance coverage, and as long as constructive
negotiations with PREPA are underway, the guarantors are likely to report relatively small loss reserves.
This development with PREPA is just one aspect of the ongoing Puerto Rico debt crisis. Before the July debt service payments,
Assured and MBIA each had approximately $4.9 billion in aggregate net exposure to Puerto Rico, including PREPA debt. Although the
guarantors support arrangement with PREPA was a positive step, the situation remains fluid.

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Moody's Related Research

Study Advising Debt Restructuring Casts Doubt on GO Bond Protections, June 2015 (1006242)

Puerto Rico's General Obligation Bonds Face Threat from Bill Allowing Suspension of Monthly Debt-Service Deposits, June 2015
(182696)

Puerto Rico Electric Power Authority: Frequently Asked Questions About PREPA, March 2015 (1003487)

To access any of these reports, click on the entry above. Note that these references are current as of the date of publication of this
report and that more recent reports may be available. All research may not be available to all clients.

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Endnotes
1 A distressed exchange occurs when an obligor offers creditors a new or restructured debt or a new package of securities cash or assets that amount to a
diminished financial obligation relative to the original obligation, and the exchange allows the obligor to avoid a future payment default or bankruptcy.

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policies and procedures to address the independence of MISs ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and
rated entities, and between entities who hold ratings from MIS and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at
www.moodys.com under the heading Investor Relations Corporate Governance Director and Shareholder Affiliation Policy.
For Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODYS affiliate, Moodys Investors Service Pty
Limited ABN 61 003 399 657AFSL 336969 and/or Moodys Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided
only to wholesale clients within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to
MOODYS that you are, or are accessing the document as a representative of, a wholesale client and that neither you nor the entity you represent will directly or indirectly
disseminate this document or its contents to retail clients within the meaning of section 761G of the Corporations Act 2001. MOODYS credit rating is an opinion as to the
creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail clients. It would be dangerous for retail
clients to make any investment decision based on MOODYS credit rating. If in doubt you should contact your financial or other professional adviser.
For Japan only: Moody's Japan K.K. (MJKK) is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moodys Overseas Holdings
Inc., a wholly-owned subsidiary of MCO. Moodys SF Japan K.K. (MSFJ) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical
Rating Organization (NRSRO). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a
NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan
Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.
MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred
stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any rating, agreed to pay to MJKK or MSFJ (as applicable) for appraisal and rating services rendered by it fees
ranging from JPY200,000 to approximately JPY350,000,000.
MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.

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COMMONWEALTH OF PUERTO RICO: FREQUENTLY ASKED QUESTIONS ABOUT PUERTO RICO'S FISCAL AND DEBT CRISIS

MOODY'S INVESTORS SERVICE

CROSS-SECTOR

AUTHORS
Ted Hampton
Tom Aaron
Elena Duggar
Brandan Holmes
Shivani Patel
Emily Raimes
Anne Van Praagh

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COMMONWEALTH OF PUERTO RICO: FREQUENTLY ASKED QUESTIONS ABOUT PUERTO RICO'S FISCAL AND DEBT CRISIS

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