TCREUR_Public/121012.mbx         T R O U B L E D   C O M P A N Y   R E P O R T E R

                           E U R O P E

           Friday, October 12, 2012, Vol. 13, No. 204

                            Headlines



C Y P R U S

CYPRUS ORGANISATION: Moody's Cuts CFR to 'B3'; Outlook Negative


F R A N C E

BANQUE PSA: Moody's 'D+' BFSR Remains on Review or Downgrade
PEUGEOT SA: Moody's Cuts Ratings to 'Ba3'; Outlook Negative
SOCIETE GENERALE: Fitch Affirms 'BB+' Rating on Hybrid Capital


G E R M A N Y

LANDESBANK HESSEN-THURINGEN: Moody's Reviews ABCP Programs


I R E L A N D

CELF LOAN: Moody's Upgrades Rating on Class T Notes to 'Ba1'


I T A L Y

FIAT SPA: Moody's Cuts CFR/PDR to 'Ba3'; Outlook Negative


N O R W A Y

* NORWAY: Moody's Says Banks Sensitive to Housing Deterioration


R O M A N I A

HIDROELECTRICA SA: May Get Out of Insolvency by December 31


R U S S I A

ACRON JSC: Fitch Affirms 'B+' Longterm Issuer Default Ratings
TATTELECOM OJSC: Fitch Affirms 'BB' LT Issuer Default Rating


S P A I N

NCG BANCO: Fitch Places 'BB+' Long-Term IDR on Watch Negative
* SPAIN: Moody's Says Covered Bond Issuers' Pools Vulnerable


S W I T Z E R L A N D

CREDIT SUISSE: Fitch Affirms Rating on Tier 1 Notes at 'BB+'


T U R K E Y

ARCELIK AS: Fitch Affirms 'BB+' Long-Term Issuer Default Ratings


U K R A I N E

MHP SA: Fitch Affirms 'B' Long-Term Issuer Default Ratings


U N I T E D   K I N G D O M

BARCLAYS BANK: Fitch Affirms 'BB+' Rating on Preference Shares
CLARIS LIMITED: Moody's Cuts Rating on Series 96/2007 to 'B2'
COOK AND BAKEWARE: Ceases Trading; 20 Workers Lose Jobs
COUNTRYLINER: In Administration, Contracts Terminated
ESTIA MORTGAGE: Moody's Says Citibank Downgrade No Rating Impact

HAWTHORNES OF NOTTINGHAM: KMPG Appointed as Liquidators
LCP PROUDREED: Fitch Affirms 'BBsf' Rating on GBP9.2-Mil. Notes
NOVACEM: Enters Creditors' Voluntary Liquidation
RAC FINANCE: S&P Affirms 'B+' Corp. Credit Rating; Outlook Stable
RANGERS FC: Blasts Rumors on Possible Administration

ROYAL BANK: Fitch Affirms 'BB+' Rating on Subordinated Debt
SKILLSFINDER UK: In Administration, Denies Northwood Claim
STANDARD BANK: Moody's Affirms 'D/ba2' Ratings


X X X X X X X X

* BOOK REVIEW: Legal Aspects of Health Care Reimbursement


                            *********


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C Y P R U S
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CYPRUS ORGANISATION: Moody's Cuts CFR to 'B3'; Outlook Negative
---------------------------------------------------------------
Moody's Investors Service has downgraded the corporate family
rating (CFR) of Cyprus Organisation for the Storage and
Management of Oil Stocks ("KODAP") to B3 from B1. The rating
outlook is negative.

Ratings Rationale

The downgrade of KODAP's CFR follows the action initiated by
Moody's on Cyprus's government bond ratings, which were
downgraded to B3 from Ba3 on 8 October 2012.

The alignment of KODAP's rating with the rating of the Government
of Cyprus reflects the fact that KODAP is a key instrument for
the Cypriot government's compliance with EU regulations relating
to national stocks of oil and oil products. KODAP is a public law
entity and operates under the close supervision of the Cypriot
government. It enjoys governmental support under a clear and
specific framework established by law. Although the State does
not grant an explicit guarantee to KODAP's liabilities, it
assumes residual responsibility for any liability at liquidation,
which can only be decided by Order of the Council of Ministers.
This strong support combined with a limited degree of autonomy
leads Moody's to use a credit substitution (CS) approach and
assign to KODAP a rating at the government's rating level instead
of applying the more granular GRI framework of assigning a BCA
and assumptions on both support and dependence to assign such
rating.

Moody's considers that at the current level of the sovereign
rating, it is no longer warranted to position KODAP's rating one
notch below that of the Government of Cyprus. It believes that
the risks associated with the lack of an explicit guarantee from
the Cypriot government, are mitigated by the level of asset-
backing enjoyed by KODAP's creditors owing to the strategic oil
reserves owned by the company. At the end of 2011, these reserves
had a book and market value estimated at EUR114 million and
around EUR160 million respectively.

The negative rating outlook on KODAP mirrors the negative outlook
maintained on the sovereign rating of Cyprus, as further
deterioration in the latter would likely result in a downgrade of
KODAP's rating. It is unlikely that Moody's would revise KODAP's
rating outlook to stable without a revision of the outlook for
Cyprus's rating, as well as updated information on the financial
position of KODAP, which has yet to publish its audited financial
statements for the year ended 31 December 2011.

In the absence of a change in the nature and standalone profile
of KODAP or the perceived strength of underlying sovereign
support, a further downgrade in the rating of KODAP would most
likely be driven by a downgrade in the rating of Cyprus. In view
of the action, and the recent action on the sovereign rating, no
positive rating pressure is currently envisaged in the short-term
for KODAP.

Cyprus Organisation for the Storage and Management of Oil
Stocks's ratings were assigned by evaluating factors that Moody's
considers relevant to the credit profile of the issuer, such as
the company's (i) business risk and competitive position compared
with others within the industry; (ii) capital structure and
financial risk; (iii) projected performance over the near to
intermediate term; and (iv) management's track record and
tolerance for risk. Moody's compared these attributes against
other issuers both within and outside Cyprus Organisation for the
Storage and Management of Oil Stocks's core industry and believes
Cyprus Organisation for the Storage and Management of Oil
Stocks's ratings are comparable to those of other issuers with
similar credit risk. Other methodologies used include the
Government-Related Issuers: Methodology Update published in July
2010.

KODAP, domiciled in Nicosia, Cyprus, is the organization
responsible for maintaining compulsory strategic reserves of
petroleum products in Cyprus equivalent to a minimum of 90 days
of national consumption. In 2010, KODAP reported revenues of
EUR23.8 million and a net surplus of EUR6.4 million.



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F R A N C E
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BANQUE PSA: Moody's 'D+' BFSR Remains on Review or Downgrade
------------------------------------------------------------
Moody's Investors Service said that the D+ Bank Financial
Strength Rating (BFSR) and Baa3 long-term debt and deposit
ratings of Banque PSA Finance (BPF) remain on review for
downgrade, following the downgrade of its parent Peugeot S.A.
(PSA)' s senior unsecured debt ratings to Ba3 from Ba2 on 10
October 2012 (for more details on this rating action, please
refer to the press release "Moody's downgrades Peugeot to Ba3;
negative outlook"). The bank's Prime-3 short-term debt and
deposit ratings, its (P)Ba1 subordinated and (P)Ba2 junior
subordinated debt program ratings, as well as Peugeot Finance
International N.V.'s Baa3 backed senior unsecured rating and the
P-3 backed commercial paper rating of SOFIRA SNC, two
subsidiaries of BPF, also remain on review for downgrade.

BPF's ratings were placed on review for possible downgrade on
July 17, 2012, following Moody's announcement of a review on PSA.
The review was maintained following the downgrade of PSA to Ba2
from Ba1 on July 26, 2012, and the subsequent downgrade of BPF to
Baa3 from Baa2. Moody's expects to conclude its review for
possible downgrade on BPF's ratings in the coming weeks.

Ratings Rationale

BPF's long-term ratings reflect the bank's fundamentals including
Moody's view that BPF's creditworthiness is inherently linked to
that of PSA, given the intricate strategic, commercial and
financial ties to its parent. These credit linkages with PSA
include (i) BPF's dependence on PSA for its own business
rationale and franchise value; (ii) the potential, therefore, for
adverse developments at PSA to impact BPF's funding capacity;
(iii) the ability of PSA to require BPF to pay exceptional
dividends (Moody's notes that a EUR360 million exceptional
dividend was paid in 2012); (iv) BPF's credit exposures to PSA's
car dealer networks; and, (v) BPF's exposures to the value of the
PSA vehicles it finances, which provide the collateral against
its loan book. On the other hand, Moody's recognizes that BPF's
financial performance has thus far displayed low correlation with
that of the car manufacturer, and that its credit profile is
otherwise healthier considering the bank's good capitalization
and profitability track record, and its policy of maintaining a
positive liquidity gap.

The ongoing review will now consider the impact on BPF of the
downgrade to Ba3 of its parent in the context of the current weak
economic environment, including any actions which BPF might take
to reduce its correlation with PSA, or otherwise to protect its
own creditworthiness.

What Could Change The Rating Up

Moody's believes there is little likelihood of any upward rating
pressure on BPF, given the current rating of PSA and the weak
economic and financing conditions.

What Could Change The Rating Down

A downgrade in BPF's long-term ratings could result from the
downgrade of PSA, absent any factors which in Moody's view could
reduce the intrinsic links and correlation between the bank and
the manufacturer. BPF's ratings could also be downgraded due to a
deterioration in its credit fundamentals, for example an increase
in credit losses or more difficult refinancing conditions.
However, a downgrade may be limited by evidence of potential
external support, which is currently not factored into the bank's
ratings.

The principal methodology used in these ratings was Moody's
Consolidated Global Bank Rating Methodology published in June
2012.


PEUGEOT SA: Moody's Cuts Ratings to 'Ba3'; Outlook Negative
-----------------------------------------------------------
Moody's Investors Service has downgraded to Ba3 from Ba2 the
ratings of Peugeot S.A. ("PSA") and its rated subsidiary GIE PSA
Tresorerie ("GIE"). This concludes the review initiated by
Moody's on 26 July 2012. The outlook on the ratings is negative.

Downgrades:

  Issuer: GIE PSA Tresorerie

    Senior Unsecured Regular Bond/Debenture, Downgraded to Ba3
    from Ba2

  Issuer: Peugeot S.A.

     Probability of Default Rating, Downgraded to Ba3 from Ba2

     Corporate Family Rating, Downgraded to Ba3 from Ba2

    Senior Unsecured Conv./Exch. Bond/Debenture, Downgraded to
    Ba3 from Ba2

    Senior Unsecured Medium-Term Note Program, Downgraded to
    (P)Ba3 from (P)Ba2

    Senior Unsecured Regular Bond/Debenture, Downgraded to Ba3
    from Ba2

Outlook Actions:

  Issuer: GIE PSA Tresorerie

    Outlook, Changed To Negative From Rating Under Review

  Issuer: Peugeot S.A.

    Outlook, Changed To Negative From Rating Under Review

Ratings Rationale

"The rating action reflects the significant challenges facing PSA
to successfully restructure and turn around the operating
performance of its automotive operations, including achieving the
targeted break-even operating cash flow by 2014. Even if these
measures are timely implemented, these circumstances will stress
the company's metrics much beyond the existing rating category
for the next couple of years," says Falk Frey, a Moody's Senior
Vice President and lead analyst for PSA. "Given that we
anticipate a further decline of 3% in light vehicle demand and
increased pricing pressure in western Europe in 2013, PSA's
announced initiatives may not be sufficient for the group to
realise the financial results it is targeting within its
restructuring plan which is reflected in the negative outlook,"
adds Mr. Frey.

PSA faces significant challenges in its efforts to turn around
its loss-making automotive business and to reduce the currently
high cash burn within its operations by implementing announced
initiatives to reduce fixed costs and adjust capacities. These
challenges are exacerbated by a worsening market environment in
PSA's key European markets, with declining car demand and
increasing price pressure, especially in the small car segments.
In particular, as Moody's currently expects the downward trend in
new car sales in western Europe to continue well into 2013, PSA
might need to take further actions in order to stabilize its
operations and achieve the targeted turnaround as announced.
Based on Moody's calculations, should car demand in Europe remain
at current low levels, the initiated reduction in capacity at
Aulnay and Rennes of approximately 300,000 units might not be
sufficient for PSA to achieve sustainably solid profitability
well above break-even.

PSA has undertaken various initiatives aimed at improving its
competitive positioning and operating performance (including new
product launches and EUR1.0 billion cost reduction plan), as well
as asset disposals and a capital increase of EUR1.1 billion to
improve its balance sheet. The anticipated cash inflow from the
asset disposals was intended to provide the resources and time
that would allow PSA to implement the necessary operational and
structural measures to turn around the core automotive business
by 2014. However, a more adverse market environment and a further
deterioration in pricing and car demand in Europe, PSA's key
market, could result in a slower-than-anticipated reduction in
the group's cash burn rate and thus erode over time its currently
solid liquidity position, as discussed below. Following PSA's
recent asset disposal program, Moody's notes that the group has
limited remaining assets available for sale.

For H2 2012, Moody's anticipates that PSA's results will be
adversely affected by its restructuring provisions for its
announced plant reorganization, with most of the cash outflow to
occur in 2013. Moody's expects the automotive division's reported
recurring operating income to remain negative in 2013 before
turning positive in 2014, which assumes timely implementation of
PSA's recently announced restructuring plan.

Moody's notes that PSA's announced strategic alliance with
General Motors (Ba1 positive), which is structured around sharing
selected vehicle platforms, components and modules as well as a
global purchasing joint venture, might result in medium to long-
term cost savings for PSA. However, Moody's cautions that upfront
expenses will negatively affect PSA's results in the short term.
Moody's also notes that a number of past mergers and alliances in
the automotive industry have not achieved the anticipated
competitive advantages and improved performance.

The negative outlook on the ratings reflects the significant
challenges PSA faces to turn around its loss-making automotive
business and reduce the currently high cash burn within its
operations, with the group needing to rapidly and successfully
implement its announced initiatives to reduce fixed costs and
adjust capacities. These challenges are exacerbated by a
worsening market environment in PSA's key European markets, with
declining car demand and rising price pressure especially in the
small car segment. A further weakening in car demand in PSA's key
geographies could lead to renewed pressure on the ratings and
require the group to take additional measures to sustainably turn
around the operating performance of its automotive operations.

What Could Change The Ratings Up/Down

Moody's could further downgrade the ratings if PSA is unable to
demonstrate that its announced measures are yielding the targeted
results, including a clear path towards break-even operational
free cash flow by end 2014. Therefore, Moody's would expect PSA
to cut its current negative cash burn of EUR200 million per month
to no more than EUR100 million per month in 2013 (excluding
restructuring costs), resulting in the company exhibiting
negative free cash flow of less than EUR1.2 billion for the full
year 2013. In addition, a downgrade could result if PSA (1) is
unable to limit the recurring operating losses before
restructuring provisions in its industrial divisions division to
EUR500 million or less in 2013; and (2) fails to stabilize its
market shares in Europe given the renewal of key volume models.
Moreover, key to PSA sustaining its liquidity profile, and its
current rating, is the successful completion of its announced
disposal of its logistics operations, Gefco.

Moody's considers that an upgrade over the short to medium term
is unlikely. However, the ratings could come under upward
pressure in there were to be a faster-than-anticipated and
sustained recovery in the operating performance and cash
generation of the PSA's automotive business. This recovery would
be reflected by positive operating profits in the industrial
business in 2013, with profitability improving to a positive EBIT
margin by 2014 and beyond.

Liquidity

Moody's notes that PSA currently maintains an adequate liquidity
position, which provides the company with a period of time to
execute a turnaround in its performance. At the end of June 2012,
PSA's principal liquidity sources for its industrial business
consisted of (1) cash on the balance sheet amounting to EUR7.5
billion; (2) availability under undrawn committed credit lines of
EUR2.4 billion maturing July 2015 (excluding additional headroom
of EUR600 million under Faurecia's facility); and (3) potential
cash flow generation from operations over the next 12 months.
These cash sources provide adequate coverage for PSA's major
liquidity requirements that could arise during the next 12
months. These requirements consist of short-term debt maturities,
capital expenditures, working capital funding and day-to-day
operating needs.

Structural Considerations

Peugeot's funding policy is based on borrowing at the holding
company level (Peugeot S.A.), and on-lending to its operating
subsidiaries via GIE PSA Tresorerie. Based on a cash-pooling
agreement between PSA and GIE, all operating subsidiaries'
payment obligations to GIE rank pari-passu with trade payables at
the subsidiaries' level. In addition, Moody's understands that,
before year end, PSA will put in place a guarantee by GIE to that
will benefit PSA bondholders. Therefore, the ratings of PSA's
outstanding notes and bonds are not notched below the group's CFR
according to Moody's Loss Given Default Methodology.

Rating Methodology Used

The principal methodology used in rating PSA was the "Global
Automobile Manufacture Industry" rating methodology, published in
June 2011. Other methodologies used include "Loss Given Default
for Speculative-Grade Non-Financial Companies in the U.S., Canada
and EMEA", published in June 2009.

Peugeot S.A., headquartered in Paris, is Europe's second-largest
maker of light vehicles with its two main brands Peugeot and
Citro‰n. The group's other industrial operations include
Faurecia, one of Europe's leading automotive suppliers in which
PSA held a 57.43% interest at year-end 2010, and Gefco, France's
second-largest transportation and logistics service provider. The
group also provides financing to dealers and end-customers
through its wholly owned finance subsidiary, Banque PSA Finance.
In 2011, PSA generated revenues of EUR59.9 billion and operating
income of EUR0.9 billion.


SOCIETE GENERALE: Fitch Affirms 'BB+' Rating on Hybrid Capital
--------------------------------------------------------------
Fitch Ratings has affirmed Societe Generale's (SG) Long-term
Issuer Default Rating (IDR) at 'A+' with a Negative Outlook and
Short-term IDR at 'F1+'.  At the same time, the agency has
affirmed the Viability Rating (VR) at 'a-', Support Rating Floor
at 'A+' and Support Rating at '1'.

Rating Action Rationale

SG's Long- and Short-term IDRs, Support Rating and Support Rating
Floor continue to reflect potential support from France
('AAA'/Negative), if required.  The Negative Outlook on SG's
Long-term IDR reflects that on France's Long-term IDR.

This rating action on SG was taken in conjunction with Fitch's
Global Trading and Universal Bank (GTUB) periodic review.
Fitch's outlook for the industry is stable on balance.  The
positive rating drivers include improved liquidity, funding,
capitalization and more streamlined businesses, all partly driven
by regulation.  Offsetting these positive drivers are substantial
earnings pressure, regulatory uncertainty and heightened legal
and operational risk.

RATING DRIVERS AND SENSITIVITIES - IDRS, SUPPORT RATING AND
SUPPORT RATING FLOOR

SG's Long- and Short-term Term IDRs are driven by potential
support and the Long-term IDR is at the same level as its Support
Rating Floor.  The Long- and Short-term IDRs, Support Rating and
Support Rating Floor are sensitive to a decrease in France's
ability (as measured by its rating) and willingness to support
SG.  A downgrade of France's Long-term IDR by one notch (to
'AA+') would lead to a downgrade of SG's Support Rating Floor and
Long-term IDRs to 'A' and Short-term IDR to 'F1'.  The ratings
are also sensitive to a change in Fitch's assumptions around the
availability of sovereign support for the bank.  In this context,
Fitch is paying close attention to on-going policy discussions
around bank support and 'bail in', especially in Europe.  An
upgrade of SG's IDRs is unlikely given Fitch's expectation of
diminishing sovereign support for banks generally in Europe and
globally.

RATING DRIVERS AND SENSITIVITIES - VR

SG's VR reflects its franchise in retail banking and corporate
and investment banking (CIB), notably in equities, and its focus
on strengthening its balance sheet in terms of both liquidity and
capital.  However, the VR also considers the bank's volatile and
currently mediocre profitability as well as its dependence on
capital markets activity, where it has a second-tier ranking in
fixed-income products.  The VR is negatively affected by exposure
through commercial bank subsidiaries in CEE/Russia, which are
showing disappointing results.  Further negative VR drivers
include a high gross impaired loans ratio, low -- albeit
improving -- capitalization given SG's business mix and a lower
quality liquidity buffer than those at other GTUBs.

The bank's VR could be downgraded if it does not generate higher
returns in CEE/Russia, does not continue to strengthen capital
ratios and/or does not increase its stock of high quality liquid
assets.  Moreover, higher risk in its CIB or international retail
banking businesses could lead to negative rating pressure. Fitch
does not expect to upgrade SG's VR in the near term.

SUBORDINATED DEBT AND OTHER HYBRID SECURITIES

Subordinated debt and other hybrid capital issued by SG and SG
Capital Trust III are all notched down from SG's VR in accordance
with Fitch's assessment of each instrument's respective non-
performance and relative loss severity risk profiles, which vary
considerably.  Their ratings are primarily sensitive to any
change in SG's VR.

SUSBIDIARY AND AFFILIATED COMPANY RATING DRIVERS AND
SENSITIVITIES

The Long-and Short-term IDRs and Support Rating of SG's French
subsidiary, Societe Generale SFH, is based on an extremely high
probability of support from SG if needed and are therefore
sensitive to changes in SG's IDRs.  The ratings of this
subsidiary could also be sensitive to changes in its strategic
importance to the rest of the group.

Societe Generale Acceptance N.V., SG Option Europe and SG
Structured Products Inc. are wholly owned financing subsidiaries
of SG whose debt ratings are aligned with that of SG based on an
extremely high probability of support if required and whose
ratings are sensitive to the same factors that might drive a
change in SG's IDR.

The rating actions are as follows:

Societe Generale

  -- Long-term IDR: affirmed at 'A+'; Outlook Negative
  -- Short-term IDR: affirmed at 'F1+'
  -- Viability Rating: affirmed at 'a-'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A+'
  -- Commercial paper: affirmed at 'F1+'
  -- Senior unsecured debt: affirmed at 'A+'/'F1+'
  -- Short-term debt: affirmed at 'F1+'
  -- Lower Tier 2 notes: affirmed at 'BBB+'
  -- Hybrid capital instruments: affirmed at 'BB+'

Societe Generale SFH

  -- Long-term IDR: affirmed at 'A+'; Outlook Negative
  -- Short-term IDR: affirmed at 'F1+'
  -- Support Rating: affirmed at '1'
  -- Mortgage Covered Bonds: 'AAA' Unaffected

Societe Generale Acceptance N.V.

  -- Market-linked guaranteed notes: affirmed at 'A+emr'
  -- Senior notes: affirmed at 'A+'/'F1+'
  -- Senior guaranteed notes: affirmed at 'A+'

SG Option Europe

  -- Market-linked guaranteed notes: affirmed at 'A+emr'
  -- Senior notes: affirmed at 'A+'/'F1+'

SG Capital Trust III

  -- Preferred stock: affirmed at 'BB+'

SG Structured Products Inc.

  -- Senior notes: affirmed at 'A+'



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G E R M A N Y
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LANDESBANK HESSEN-THURINGEN: Moody's Reviews ABCP Programs
----------------------------------------------------------
Moody's Investors Service took ABCP rating actions for the seven-
day period ending October 8, 2012.

NO RATING IMPACT ON THE FOLLOWING ABCP PROGRAMS DURING THE PERIOD
OCTOBER 2, 2012 THROUGH OCTOBER 8, 2012:

Moody's has reviewed the following ABCP programs in conjunction
with the proposed amendments. The amendments, in and of
themselves and at this time, will not result in any rating impact
on the respective programs. For the mentioned programs, Moody's
believes that the amendments do not have an adverse effect on the
credit quality of the securities such that the Moody's ratings
are impacted. Moody's does not express an opinion as to whether
the amendment could have other, non-credit-related effects.

HSBC'S REGENCY AND HELABA'S OPUSALPHA PARTICIPATE IN AUTO LEASE
TRANSACTION

Regency Assets Ltd/Regency Markets No.1 LLC ("Regency"), a
partially supported, multiseller conduit sponsored by HSBC Bank
Plc ("HSBC", Aa3/Prime-1/C) and Opusalpha Funding Limited, a
partially supported, hybrid ABCP program sponsored by Landesbank
Hessen-Thueringen GZ ("Helaba", rated A2/Prime-1/D+) have
participated in a co-purchase of a UK auto lease transaction. The
transaction is sized at GBP500 million and the leases are
originated by a UK finance subsidiary of a German car
manufacturer. Both Regency's and Opusalpha's commitments are for
GBP250 million.

In Regency, the transaction is fully supported through a GBP255
million liquidity facility, which is provided by Prime-1 rated
HSBC and sized at 102% of the purchase limit. The liquidity
facility has a liability-based borrowing base which ensures full
and timely repayment of the associated face ABCP.

Regency's program-level credit enhancement was not increased with
this transaction since the transaction was fully-supported.
Regency has approval to issue ABCP up to aggregate transaction
limits of US$9.8 billion and has US$158 million in program-level
credit enhancement.

In Opusalpha, this transaction is fully supported through a
GBP255 million liquidity facility provided Helaba. The liquidity
facility will be available in GBP for an amount equal to the
outstanding amount of the aggregate investment made by Opusalpha
under the transaction, plus all related funding costs, therefore
covering the face amount of ABCP issued to fund this transaction.

With this transaction, Opusalpha's aggregate purchase limit
equals to EUR2,136 million. Opusalpha's program-level credit
enhancement, which is provided by Helaba, is at EUR44.3 million
and was not increased following this transaction.

HSBC'S BRYANT PARK AMENDS EXISTING TRADE RECEIVABLE FACILITY

Bryant Park Funding LLC ("Bryant Park"), a partially supported,
multiseller ABCP conduit administered by HSBC Securities (USA)
Inc., has amended an existing a US$275 million interest in a
revolving trade receivables facility for an unrated cement
manufacturer and distributor. The facility will be increased to
US$325 million to accommodate the addition of receivables from
two new originators.

Transaction-specific credit enhancement is in the form of
overcollateralization equal to a minimum of 17% of eligible
receivables. This transaction is partially supported by a
liquidity facility provided by HSBC Bank Plc.

With this transaction, Bryant Park's program-level credit
enhancement increased by 8% of outstanding ABCP issued to finance
the transaction. Bryant Park has approximately $2.5 billion of
outstanding CP and its program-level credit enhancement is $305
million.

SOCIETE GENERALE'S ANTALIS PURCHASES EURO 28 MILLION SENIOR NOTES
BENEFITING OF Aaa GUARANTEE

Antalis S.A./Antalis U.S. Funding Corp. (together, "Antalis"), a
partially supported, multiseller program sponsored by Societe
Generale ("SocGen", rated A2/Prime-1/C-), has purchased A3 (sf)
rated senior notes issued by a Spanish SPV for an amount up to
EUR28 million. Concurrently, Antalis entered into a first demand,
unconditional and irrevocable guarantee agreement provided by Aaa
supranational entity. The guarantee covers timely payment of
interest and ultimate payment of principal on the subscribed
senior notes.

The transaction is a static cash securitization of credit rights
derived from lease contracts extended to small, micro and medium
enterprises (SMEs) and self-employed individuals located in
Spain.

The transaction is partially supported by a liquidity facility
provided by SocGen. The liquidity facility funds for the face
value of the ABCP as long as the guarantor's rating is Caa2 or if
it was at least Caa2 immediately before Moody's withdraws the
rating. ABCP can be issued as long as the guarantor's rating is
not withdrawn or is at least equal to Aa3. The maximum term of
ABCP is 270 days.

Investors are exposed to the risk that Moody's downgrades the
guarantor's rating to Caa3 from Aa3 within 270 days. Moody's
assesses that this situation is unlikely to take place due the
status of the guarantor, its current rating and rating outlook.
In addition, the deal is static and benefits from a short
weighted average life (less than 2 years). As the structure
solely relies on the guarantor's rating independently of whether
the guarantee agreement is in place, Moody's analysis does not
rely on the existence of the guarantee agreement.

With this transaction, Antalis' s program-level credit
enhancement increased by 6% of the purchase limit to Euro 263
million. Antalis is authorized to issue approximately EUR 4.5
billion of ABCP.

The principal methodology used in these ratings was "Moody's
Approach to Rating Asset-Backed Commercial Paper" published in
May 2012.



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I R E L A N D
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CELF LOAN: Moody's Upgrades Rating on Class T Notes to 'Ba1'
------------------------------------------------------------
Moody's Investors Service upgraded the EUR76 million CLO notes of
CELF Loan Partners II plc.

Moody's also confirmed EUR62 million CLO notes of CELF Loan
Partners II plc.

Issuer: CELF Loan Partners II plc

    EUR50M Class B-1 Senior Secured Floating Rate Notes due 2021
    Notes, Upgraded to A1 (sf); previously on Jul 10, 2012 A2
    (sf) Placed Under Review for Possible Upgrade

    EUR7M Class B-2 Senior Secured Fixed Rate Notes due 2021
    Notes, Upgraded to A1 (sf); previously on Jul 10, 2012 A2
    (sf) Placed Under Review for Possible Upgrade

    EUR12M Class T Combination Notes Notes, Upgraded to Ba1 (sf);
    previously on Jul 5, 2011 Upgraded to Ba2 (sf)

    EUR42.5M Class C Senior Secured Deferrable Floating Rate
    Notes due2021 Notes, Confirmed at Ba1 (sf); previously on Jul
    10, 2012 Ba1 (sf) Placed Under Review for Possible Upgrade

    EUR19.5M Class D Senior Secured Deferrable Floating Rate
    Notes due 2021 Notes, Confirmed at B1 (sf); previously on Jul
    10, 2012 B1 (sf) Placed Under Review for Possible Upgrade

The ratings of the Combination Notes address the repayment of the
Rated Balance on or before the legal final maturity. For Class T,
the 'Rated Balance' is equal at any time to the principal amount
of the Combination Note on the Issue Date minus the aggregate of
all payments made from the Issue Date to such date, either
through interest or principal payments. The Rated Balance may not
necessarily correspond to the outstanding notional amount
reported by the trustee.

CELF Loan Partners II PLC., issued in November 2005, is a single-
currency Collateralised Loan Obligation ("CLO") backed by a
portfolio of mostly high yield European loans. The portfolio is
managed by CELF Advisors LLP. The reinvestment period ended in
December 2011. It is predominantly composed of senior secured
loans.

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of the deleveraging of the senior notes since
the last rating action in July 2011. The actions also reflect a
correction to the rating model that Moody's used for this
transaction. Moody's corrected the rating model and put the
ratings of the above tranches on review for upgrade on July 10,
2012.

Moody's notes that the Class A notes have been paid down by
approximately 10% or EUR28.5 million since the rating action in
July 2011. The overcollateralization ratios of the rated notes
have been relatively stable since the rating action in July 2011.
The Class A/B, Class C and Class D overcollateralization ratios
are reported at 127.10%, 111.78% and 105.92%, respectively,
versus June 2011 levels of 126.81%, 112.66% and 107.18%,
respectively, and all related overcollateralization tests are
currently in compliance. Additionally, defaulted securities total
about EUR6 million of the underlying portfolio compared to
EUR11.5 million in June 2011. Reported weighted averaged spread
has increased from 3.50% to 4.03% between June 2011 and September
2012.

Reported WARF has increased slightly from 2987 to 3003 between
June 2011 and September 2012. Securities rated Caa or lower make
up approximately 11.66% of the underlying portfolio versus 9.71%
in June 2012;

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as the portfolio par amount, WARF,
diversity score, and weighted average recovery rate, may be
different from the trustee's reported numbers. In its base case,
Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of EUR397.5
million, defaulted par of EUR7.9 million, a weighted average
default probability of 20.53% (consistent with a WARF of 2836), a
weighted average recovery rate upon default of 44.43% for a Aaa
liability target rating, a diversity score of 36 and a weighted
average spread of 3.97%. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average
recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
For a Aaa liability target rating, Moody's assumed that 85% of
the portfolio exposed to senior secured corporate assets would
recover 50% upon default, while the remainder non first-lien loan
corporate assets would recover 10%. In each case, historical and
market performance trends and collateral manager latitude for
trading the collateral are also relevant factors. These default
and recovery properties of the collateral pool are incorporated
in cash flow model analysis where they are subject to stresses as
a function of the target rating of each CLO liability being
reviewed.

In the process of determining the final ratings, Moody's took
into account the results of a number of sensitivity analyses:

(1) Deterioration of credit quality to address the refinance and
sovereign risks -- Approximately 20% of the portfolio are rated
B3 and below and maturing between 2014 and 2016, which may create
challenges for issuers to refinance. Approximately 12% of the
portfolio is exposed to obligors located in Greece, Portugal,
Ireland, Spain and Italy. Moody's considered a model run where
the base case WARF was increased to be 3672 by forcing ratings on
25% of such exposure to Ca. This run generated model outputs that
were one to three notches lower than the base case results.

(2) Lower Weighted Average Spread - To test the deal sensitivity
to key parameters, Moody's modelled a lower weighted average
spread of 3.53%, which is the midpoint between reported and
covenanted values. This run generated model outputs that were
within one notch off the base case results.

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, which could negatively impact the
ratings of the notes, as evidenced by 1) uncertainties of credit
conditions in the general economy and 2) the large concentration
of speculative-grade debt maturing between 2014 and 2016 which
may create challenges for issuers to refinance. CLO notes'
performance may also be impacted either positively or negatively
by 1) the manager's investment strategy and behavior and 2)
divergence in legal interpretation of CDO documentation by
different transactional parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

1) Deleveraging: The main source of uncertainty in this
transaction is the pace of amortization of the underlying
portfolio. Pace of amortization could vary significantly subject
to market conditions and this may have a significant impact on
the notes' ratings. In particular, amortization could accelerate
as a consequence of high levels of prepayments in the loan market
or collateral sales by the Collateral Manager or be delayed by
rising loan amend-and-extent restructurings. Fast amortization
would usually benefit the ratings of the notes.

2) Moody's also notes that around 57% of the collateral pool
consists of debt obligations whose credit quality has been
assessed through Moody's credit estimates. Further information
regarding specific risks and stresses associated with credit
estimates are available in the report titled "Updated Approach to
the Usage of Credit Estimates in Rated Transactions" published in
October 2009.

3) Recovery of defaulted assets: Market value fluctuations in
defaulted assets reported by the trustee and those assumed to be
defaulted by Moody's may create volatility in the deal's
overcollateralization levels. Further, the timing of recoveries
and the manager's decision to work out versus sell defaulted
assets create additional uncertainties. Moody's analyzed
defaulted recoveries assuming the lower of the market price and
the recovery rate in order to account for potential volatility in
market prices. Realization of higher than expected recoveries
would positively impact the ratings of the notes.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in June 2011.

The cash flow model used for this transaction, whose description
can be found in the methodology listed above, is Moody's CDOEdge
model.

This model was used to represent the cash flows and determine the
loss for each tranche. The cash flow model evaluates all default
scenarios that are then weighted considering the probabilities of
the binomial distribution assumed for the portfolio default rate.
In each default scenario, the corresponding loss for each class
of notes is calculated given the incoming cash flows from the
assets and the outgoing payments to third parties and
noteholders. Therefore, the expected loss or EL for each tranche
is the sum product of (i) the probability of occurrence of each
default scenario; and (ii) the loss derived from the cash flow
model in each default scenario for each tranche.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of the rating committee
considerations. These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record,
and the potential for selection bias in the portfolio. All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.



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FIAT SPA: Moody's Cuts CFR/PDR to 'Ba3'; Outlook Negative
---------------------------------------------------------
Moody's Investors Service has downgraded the corporate family
rating (CFR) and probability of default rating (PDR) of Fiat
S.p.A. to Ba3 from Ba2. Concurrently, Moody's has also downgraded
the debt issued by Fiat's rated subsidiaries Fiat Finance & Trade
and Fiat Finance North America to B1 from Ba3 as well as the
rating of Fiat Finance Canada to (P)B1 from (P)Ba3. The outlook
on the ratings is negative.

Downgrades:

  Issuer: Fiat Finance & Trade Ltd.

    Senior Unsecured Medium-Term Note Program, Downgraded to
    (P)B1 from (P)Ba3

    Senior Unsecured Regular Bond/Debenture, Downgraded to B1
    from Ba3

    Senior Unsecured Regular Bond/Debenture, Downgraded to B1
    from Ba3

    Senior Unsecured Regular Bond/Debenture, Downgraded to B1
    from Ba3

  Issuer: Fiat Finance Canada Ltd.

    Senior Unsecured Medium-Term Note Program, Downgraded to
    (P)B1 from (P)Ba3

  Issuer: Fiat Finance North America Inc.

    Senior Unsecured Medium-Term Note Program, Downgraded to
    (P)B1 from (P)Ba3

    Senior Unsecured Regular Bond/Debenture, Downgraded to B1
    from Ba3

  Issuer: Fiat S.p.A.

     Probability of Default Rating, Downgraded to Ba3 from Ba2

     Corporate Family Rating, Downgraded to Ba3 from Ba2

    Senior Unsecured Medium-Term Note Program, Downgraded to
    (P)B1 from (P)Ba3

Ratings Rationale

"The one-notch downgrade of Fiat's ratings to Ba3 reflects the
decline in demand for Italian cars recorded so far this year and
in our outlook for demand till the end of 2012 and beyond. Italy
represents more than half of Fiat's European car registrations
and as such the deterioration is the key driver of the rising
losses among its mass market brands and of its cash consumption
in EMEA region," says Falk Frey, a Moody's Senior Vice President
and lead analyst for Fiat.

Although Fiat's consolidated financial results benefit from the
improving performance of Chrysler Group LLC, the Fiat bondholders
do not have full access to the cash flows from this entity, nor
does Moody's anticipate a major change in this access over the
short term. "This leads Moody's to expect further deterioration
in Fiat's standalone credit metrics in 2012, with limited
improvement likely in 2013," Mr. Frey adds.

When disaggregating Chrysler's financials from Fiat's
consolidated accounts, it becomes clear that Fiat's standalone
credit metrics have deteriorated over recent quarters, as
evidenced by an adjusted debt/EBITDA of around 8.0x and negative
free cash flow of approximately EUR2.8 billion in the last twelve
months ending in June 2012.

Fiat's mass market brands (excluding Chrysler) are not only very
reliant on the European passenger car market, which represents
around 60% of revenues, but are also heavily focused on the
Italian market, which accounted for 52% of Fiat & Chrysler's
registrations for the period January-August 2012. Moody's
anticipates western European light vehicle demand to decline by
8% in the current year and a further 3% in 2013. Moody's projects
demand in Italy to contract by 20% this year and to stabilize
(+1.4%) at that low level next year. In addition, rising price
pressures and rebates in Europe will exacerbate the negative
effect on Fiat's performance. Moody's notes that the Luxury and
Performance brands business supported the overall Group
performance with an EBIT of EUR175 million in H1 '12 and an EBIT
margin of 12.2%.

In Italy, Fiat is facing significant overcapacities despite the
closure of its factory in Sicily at the end of last year. In
Moody's opinion, Fiat original target of reaching a break-even
point in trading profits from the EMEA region by 2014 has become
very challenging in this much worsened environment, especially in
light of current year trading losses for the Region, which
Moody's expects around EUR800 million for the current year.
Moreover, the company intends to achieve its target without any
further immediate capacity adjustments but instead plans to
increase the production of Chrysler Group models on its European
platforms in order to increase its scale and lower its unit
costs.

Furthermore, Moody's cautions that the delay in model renewals
and the absence of any major new volume model launch might
further derail Fiat's competitive position in Europe, against the
background of major new model launches from its competitors
Peugeot (208) and Renault (Clio). Fiat's also renews existing
models, in Moody's view, less frequently overall than its direct
peers. These slower renewals are constraining Fiat's competitive
position, as reflected in the group's market share losses since
2010 in Western Europe .

The Ba3 rating also reflects Fiat's business risk of its pure
focus on the highly cyclical automotive industry, including
through its stake in the Chrysler Group and the activities of
Magneti Marelli (automotive components), Teksid (supplier of
engine blocks), Comau (industrial automation systems for the auto
industry).

Moody's also notes that Fiat could be vulnerable to greater
competitive pressures in Brazil, still its most profitable
market. Moody's concerns are based on the substantial additional
capacity that will be implemented over the next two to three
years within the country that will significantly outpace Moody's
market growth expectations, leading to overcapacities with the
likely consequence of declining profitability.

Moody's views as positive the inclusion of Chrysler which has
helped improve Fiat's previously very limited geographic
diversification. Moody's had previously considered this lack of
geographic diversification as a key weakness in Fiat's business
profile.

Moreover, Moody's has taken into account the potential cost
savings resulting from the increasing operational integration
between Fiat and Chrysler regarding common architecture, modules
and technologies as well as purchasing. A positive market
acceptance of Fiat's new models, including the Lancia-branded
Chrysler derivatives, would improve the currently very low
capacity utilization rates in Fiat's European plants and
positively affect fixed-cost coverage.

Fiat's ratings also benefit from its leading market position in
Brazil (with an approximate market share of 23%), which has been
the group's major source of profits and cash flows in recent
years. In addition, Fiat benefits from a dominant domestic
Italian market presence, with a market share of approximately
30%. However, sovereign austerity programs and the weakening
Italian economy as a result of the debt crisis could continue to
negatively affect car demand in the group's second key market
(after Brazil and excluding Chrysler).

The negative rating outlook reflects (i) Fiat's standalone
(excluding Chrysler) cash burn of EUR2.6 billion in the last
twelve months ending on June 30, 2012 and Fiat's challenge to
achieve break-even free cash flow in the short to medium term;
(ii) Fiat's weak model pipeline with no major volume model
introductions in the next 12-18 months which might impair the
company's market position; as well as (iii) Fiat's low capacity
utilization rate in Europe with limited visibility of
improvement.

What Could Change The Ratings Up/Down

Moody's would consider downgrading Fiat's rating further if its
standalone net industrial cash flow were to exceed a negative
EUR2.0 billion in the current year, with no indication of a
material improvement in 2013. The rating could also come under
pressure if Fiat were to lose significant market shares in Europe
and/or if the company's earnings and cash flow contribution from
its Brazilian operations, a major source of cash flow, were to
decline, most likely as a result of rising competitive pressures
from new capacities and additional market entrants.

An upgrade of Fiat's rating is currently very unlikely. For
Moody's to consider an upgrade, Fiat would have to achieve break-
even free cash flow on a standalone basis, with further
indications that it will likely achieve positive free cash flows
that it could use to reduce company debt.

Liquidity

As of June 30, 2012, Fiat's liquidity profile was adequate,
excluding Chrysler and the unknown amount of cash outflow that
would take place were Fiat to exercise its option to purchase 40%
of the current 41.5% stake of the VEBA Trust in Chrysler. As of
June 30, 2012, the FIAT group (excluding Chrysler) reported
EUR10.0 billion in cash and an undrawn EUR1.95 billion Revolving
Credit Facility maturing in July 2014. These sources should cover
Fiat's anticipated cash requirements over the next 12 months,
comprising capital expenditures, debt maturities, cash for day-
to-day needs and minority dividends.

Structural Considerations

The senior unsecured notes issued by Fiat's funding vehicles --
Fiat Finance &Trade, Fiat Finance North America and Fiat Finance
Canada, the latter not currently having any notes outstanding --
are structurally subordinated to a significant portion of debt
located at Fiat's operating subsidiaries (mainly trade payables),
with a preferred claim on the cash flows at these entities.
Consequently, the ratings of Fiat's outstanding bonds are one
notch below the group's CFR, according to Moody's Loss Given
Default Methodology.

Rating Methodology Used

The principal methodology used in rating Fiat was Moody's "Global
Automobile Manufacture Industry Methodology", published in June
2011. Other methodologies used include "Loss Given Default for
Speculative-Grade Non-Financial Companies in the U.S., Canada and
EMEA", published in June 2009.

Headquartered in Torino, Italy, Fiat S.p.A. is one of Italy's
leading industrial groups and one of Europe's largest automotive
manufacturers by unit sales. Fiat S.p.A. owns a 58.5% stake in
Chrysler Group LLC (rated B2/positive), generated consolidated
group revenues of EUR59.6 billion and reported a trading profit
of EUR2.4 billion in 2011.



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N O R W A Y
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* NORWAY: Moody's Says Banks Sensitive to Housing Deterioration
---------------------------------------------------------------
The household mortgage portfolios of Norwegian banks are
sensitive to the potential for deterioration in the Norwegian
housing market after a protracted housing boom, says Moody's
Investors Service in a new report. Banks' asset quality and their
overall creditworthiness are sensitive to housing price trends,
even though some mitigating factors limit these pressures.

The new report, entitled "Norwegian Banks: Credit Profiles Are
Sensitive to Elevated House Prices ", is available on
www.moodys.com. Moody's subscribers can access this report via
the link provided at the end of this press release.

Moody's notes that house prices climbed 7.1% in 2011 and have
further risen in recent months, with a 7.4% increase in H1 2012
alone. In the rating agency's view, market fundamentals -- such
as an increase in households' disposable income and the number of
households, or lack of growth in housing stocks -- do not fully
explain the sharp rise in housing prices since 1995. As a result,
the risk of an eventual fall in house prices is elevated.

Also threatening banks' asset quality are high levels of
household indebtedness. An average Norwegian household's debt
burden equaled almost two times its disposable annual income at
year-end 2011 (according to Norway's central bank). This high
debt level compared with European peers partly reflects the high
level of home-ownership in Norway (around 85% of households) and
tax incentives (mortgage-related interest expenses are fully
deductible).

In addition, following strong growth in covered bond funding,
banks increasingly transfer their low-risk mortgages as
collateral to covered bond issuing vehicles. These low-risk loans
are no longer available as collateral for unsecured creditors,
and banks are increasingly left with higher-risk mortgage loans
that are not eligible as covered bond collateral. This trend
elevates the risk of loan losses for banks and their unsecured
creditors in the event of a housing correction.

However, Moody's recognizes that there are mitigating factors to
banks' heightened risks to these factors, such as (1) low and
stable unemployment levels; (2) a generous social security system
supported by the strong fiscal position in Norway; (3)
substantial household wealth; (4) the current low interest-rate
environment; and (5) low -- albeit increasing -- levels of
property construction. In Moody's view, these mitigating factors
reduce the likelihood of a sudden drop in housing prices and
limit the fallout of this scenario for banks, but they do not
completely offset the aforementioned risks.



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HIDROELECTRICA SA: May Get Out of Insolvency by December 31
-----------------------------------------------------------
Romanian Business News - ACTMedia reports that Hidroelectrica
might get out of insolvency by December 31.

Quoting the company's administrator, Mediafax said the bankruptcy
of the company may cause the disappearance of a "monopoly" in the
market of services controlling the energy system and would have
as effect Romania's "getting into darkness."

"It is everybody's interest, banks, politicians, employees,
managers at Hidroelectrica to close down the procedure by 31
December 2012. It is difficult but not impossible."

Hidroelectrica out of insolvency will not look like present
Hidroelectrica.  It will be a company making profit between 80
and 100 million euro, a standard company," the report quotes
lawyer Remus Borza, the manager of Euro Insol company, the
judicial administrator of Hidroelectrica, as saying.

Meanwhile, ACTMedia, citing Mediafax, reports that Remus
Vulpescu, the special administrator of Hidroelectrica, declared
on October 4, at Bucharest Court of Appeal, that there are high
chances to save the company following reorganization and that
certain union representatives back the "smart guys" from energy.

Bucharest Court of Appeal tries the appeals filed by Alpiq
RomIndustries, Alpiq RomEnergie and Hidrosind against the
sentence to open the insolvency procedure at Hidroelectrica,
issued by Bucharest Court on 20 June.

As reported by the Troubled Company Reporter-Europe on June 22,
2012, Bloomberg News related that a Romanian court approved the
insolvency of Hidroelectica as the company looks to reorganize
itself.

Hidroelectrica SA is a Romanian state-owned hydropower producer.



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ACRON JSC: Fitch Affirms 'B+' Longterm Issuer Default Ratings
-------------------------------------------------------------
Fitch Ratings has affirmed JSC Acron's Long-term foreign and
local currency Issuer Default Ratings (IDR) at 'B+'. The Outlook
on the Long-term IDRs is Stable.  The agency has simultaneously
assigned an expected local currency senior unsecured rating of
'B+(EXP)' and a Recovery Rating of 'RR4' to the group's new
three-year RUB15bn exchange-traded rouble bond programme.

The affirmation reflects Fitch's view that Acron's financial
profile continues to offer sufficient headroom to withstand raw
material cost inflation in Russia and expected supply-driven
pricing pressure for its core products, and to support its capex
plans over the next two years.

The ratings also reflect the progress made on Acron's phosphate
mining project, with the commissioning of the Oleniy Ruchey mine
in July and the planned launch of the ore processing operations
is in Q412.  Production at the mine should ramp up to 1mtpa of
apatite concentrate during 2013 and fully cover the group's 700kt
requirements.  This will eliminate the risks associated with
Acron's dependency on a monopolistic supplier, OAO Apatit.  A new
dispute over the terms and conditions of Acron's contract
resulted in the suspension of supplies from Apatit in May 2012.
The dispute was resolved in July 2012 but led to the temporary
suspension of NPK production in June 2012.

Fitch derives additional comfort from the announced involvement
of Vnesheconombank (VEB) in the financing of the Talitsky mine
development.  The bank will pay US$226 million for a stake of 20%
minus one share in Verkhnekamsk Potash Company (VPC), the
subsidiary developing the potash site, and provide a facility of
US$1.1 billion (RUB33 billion equivalent) to support the project.
Fitch understands that Acron plans to invite other third parties
to the capital of VPC but will keep a controlling share in the
company.  This alleviates the agency's concerns about the
potential impact of a fully-debt financed expansion on Acron's
leverage.  Total capex is estimated at US$2.8 billion (including
US$560 million for the license acquired in 2008) with
commissioning in 2016.

Under Fitch's rating case, Acron's net FFO (funds from
operations) leverage increases to around 3.0x in 2014 from 2.1x
at end-2011, reflecting sustained high levels of investments and
pressure on operating cash flow from rising raw material costs
and erosion in selling prices.  For the purpose of its
projections, the agency excluded the equity and capex associated
with VPC from its forecasts.  Fitch assumes that the capital
injections for VPC will exceed its capex requirements until 2014
and incorporating them would have flattered Acron's consolidated
leverage ratios in 2012-2013.

The 2012 base case assumes low single digit growth in sales in
2012 and projects EBITDA margin at around 28%.  The 2013 base
case also assumes supply-driven pricing pressure for Acron's core
products, with a resulting low single digit drop in revenues yoy.
The 15% annual increases in natural gas prices in Russia and
other cost inflation in the country will only be partly
compensated by the group's ongoing efficiency measures and EBITDA
margin is forecast to gradually decline over the rating horizon.

Capex (excluding VPC) is assumed at around RUB10 billionn p.a.
(around 15% of sales) in 2012-2013.  Acron will invest RUB18.6
million (US$600 million) in the development of an underground
phosphate mine at Oleniy Ruchey in 2012-2017 and plans to double
its apatite concentrate capacity to 2mtpa.  The group also plans
to spend around RUB12.4 billion (US$400 million) in 2012-2015 in
a new ammonia unit with a capacity of 700tpa.  Fitch believes
that the expansion program offers some flexibility to preserve
cash should market conditions deteriorate significantly, as some
of the project could be delayed.

The rating also captures the risks associated with Acron's
opportunistic strategy.  In May 2012, the group launched a US$440
million bid for a 66% stake in Polish fertilizer producer, Azoty
Tarnow (ZAT).  Acron subsequently increased its offer by 25% and
acquired 12% of the stock of the company in July for US$102
million.  In September, ZAT agreed to merge with chemicals
producer Zaklady Azotowe in a deal that is expected to close in
Q113.  This would dilute Acron's interest but also make a further
increase in its stake considerably more costly.  Fitch does not
expect any additional offers from Acron until the merger is fully
executed.

Liquidity is adequate, with cash balances of RUB37.3 billionn at
end-Q212 against short-term debt of RUB36.8 billion. Acron's 2.9%
stake in Uralkali ('BBB-'/Stable) was worth RUB20.9 billion at
end-Q212 and could also offer additional flexibility. Fitch
forecasts mildly negative free cash flow (excluding potash
project) in 2012.  The base case assumes that Acron will be
successful in raising new debt to refinance upcoming maturities
and capex.  The group plans to issue the first of three RUB5
billion three-year tranche under its new RUB15 billion exchange-
traded bond program in October.  The bonds will be structured as
an unsecured and unsubordinated obligation of the issuer and are
not subject to any financial covenants.

WHAT COULD TRIGGER A RATING ACTION?

Positive: Future developments that may, individually or
collectively, lead to positive rating action include

  -- Successful ramp up of the phosphate project in 2013
     resulting in Acron's full vertical integration into apatite
     concentrate

  -- Neutral free cash flow (excluding potash mining capex
     financed via equity injections), leading to FFO net adjusted
     leverage maintained below 2.5x on a sustained basis

Negative: Future developments that may, individually or
collectively, lead to negative rating action include

  -- Continued negative free cash flow generation (excluding
     potash capex financed via equity injections)

  -- Significant cash outflows supporting aggressive
     distributions to shareholders and/or financial investments
     leading to FFO net adjusted leverage sustained above 3.5x

  -- A sharp deterioration in market conditions or Acron's cost
     position with a sustained drop in EBITDAR margin below 20%

The rating actions are as follows:

  -- Foreign currency long-term IDR affirmed at 'B+'; Outlook
     Stable

  -- Local currency long-term IDR affirmed at 'B+'; Outlook
     Stable

  -- Long-term national rating affirmed at 'A (rus)';

  -- Short-term foreign currency IDR affirmed at 'B';

  -- Local currency senior unsecured rating affirmed at 'B+' for
     the RUB3.5bn (series 02), RUB3.5bn (series 03), RUB3.75bn
     (series 04) and RUB3.75bn (series 05) bond issues, Recovery
     Rating 'RR4',

  -- Local currency senior unsecured rating of' B+(EXP)'/RR4
     assigned to the three-year RUB15bn exchange-traded rouble
     bond programme


TATTELECOM OJSC: Fitch Affirms 'BB' LT Issuer Default Rating
------------------------------------------------------------
Fitch Ratings has affirmed OJSC Tattelecom's (Tattel) Long-term
Issuer Default Rating (IDR) and senior unsecured rating at 'BB'
and Short-term currency IDR at 'B'.  The Outlook on the Long-term
Issuer Default Rating is Stable.

Tattel's ratings reflect its well-established positions of a
regional fixed-line incumbent dominating in the traditional
telephony and broadband segments, low leverage and robust free
cash flow generation.  However, the company's small size could
potentially limit its financial flexibility.  In addition,
liquidity management is aggressive, exposing the company to
short-term refinancing risks.

Tattel has been able to successfully defend and even grow its
market shares, most notably in the broadband segment, despite the
fierce competitive environment.  Fitch believes that the company
is likely to continue eating into its peers' market shares,
capitalizing on its good quality network and a dedicated regional
focus.  As a result, the company is facing positive revenue
growth prospects, at least in the short to medium term.

Tattel improved its broadband market share by almost 5% yoy in
2011 adding more new customers than all other operators combined.
The company launched IP-TV service at end-2009 and managed to
seize a decent market share over a short-time span with good
prospects for further progress in the pay TV segment.

Fibre upgrades should allow the company to stay ahead of the
competition in terms of network quality.  Tattel is rapidly
rolling out fibre upgrades on its network aiming to cover all
multi-storey residential houses by end-H113.  The project
investments have been moderate so far while yet to be incurred
project costs are not expected by Fitch to drive a leverage
spike.

Tattel's leverage was low at 1.0x ND/EBITDA and 1.3x FFO adjusted
leverage at end 2011, and Fitch expects it to remain relatively
modest.  The company's dividend policy of paying 30% of net
profit by Russian accounting standards and the management's focus
on high capex efficiency (as measured by such benchmarks as capex
per newly constructed line) will drive strong free cash flow
generation and deleveraging flexibility.

Tattel's liquidity is insufficient to cover its 2013 debt
maturities, which is a concern. No progress with finding
sufficient liquidity sources to cover next year's maturities by
early 2013 may prompt a negative rating action.  Tattel's
liquidity situation is mitigated by strong relationships with
local banks, flexibility to reduce capex and increase cash flow
from operations at short notice, and potential liquidity support
from the company's controlling shareholder, OJSC
Svyazinvestneftekhim (SINEK) ('BBB-'/Stable).  Refinancing
efforts will be helped by the company's overall low leverage and
the fact that a potential liquidity gap is only a small fraction
of the company's annual EBITDA.

WHAT COULD TRIGGER A RATING ACTION?

Negative: Future developments that may, individually or
collectively, lead to negative rating action include

  -- A rise in leverage to above 2.25x FFO adjusted net leverage
  -- Liquidity pressures
  -- Pronounced revenue pressures driven by market share losses,
     particularly in the broadband segment.

Positive: Further rating progress is restrained by the small size
of the company's business, lack of geographical diversification,
aggressive liquidity management and limited access to capital
markets.



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


NCG BANCO: Fitch Places 'BB+' Long-Term IDR on Watch Negative
-------------------------------------------------------------
Fitch Ratings has placed NCG Banco SA's (NCG) Support Rating (SR)
of '3' and its Support Rating Floor (SRF) of 'BB+' on Rating
Watch Negative (RWN).  As a result, its Long-term Issuer Default
Rating (IDR) of 'BB+', which is based on the moderate probability
of the authorities supporting the bank, and its Short-term IDR of
'B', have also been placed on RWN.  At the same time, Fitch has
affirmed NCG's Viability Rating (VR) of 'c'.

RATING ACTION RATIONALE AND DRIVERS - IDRs, SUPPORT RATING and
SRF

The rating actions reflect Fitch's belief that there is a
moderate probability that NCG will continue to be supported by
Spain's Fund of Orderly Bank Restructuring (FROB) with the
ultimate goal of restoring the bank's viability, after undergoing
a restructuring plan and transferring its real estate exposure to
an asset management company.

However, because of the bank's problems and high recapitalization
needs, there is heightened risk that an orderly resolution could
take place.  This could include a recapitalization plan for NCG's
future sale, but also alternative scenarios that, even if
customer depositors are fully compensated as the agency would
expect, could still qualify as some form of default or
'restricted default' under Fitch's definitions and criteria.  As
a result, the Support Rating, SRF and IDRs have been placed on
RWN.  NCG has relatively few non-customer deposit senior
unsecured liabilities on which it might be considered politically
acceptable or rational to enforce losses.

RATING ACTION RATIONALE AND DRIVERS - VR

NCG's VR has been affirmed at 'c' to reflect the exceptionally
high levels of fundamental credit risk that remain and that the
failure of the bank (under Fitch's definitions) is imminent or
inevitable.  Its exposure to the stressed Spanish real estate
market means NCG is in need of substantial recapitalization, as
was confirmed recently by the results of the stress test
undertaken by Oliver Wyman published at end-September 2012.

DATED SUBORDINATED DEBT AND OTHER HYBRID SECURITIES

NCG's dated subordinated debt has been downgraded to 'C' from
'CC' to reflect a high risk of large losses being enforced onto
these instruments in line with the burden sharing laid out in the
MOU and in Royal Decree Law 24/2012.  Its upper Tier 2 debt and
preferred stock have been affirmed at 'C' for the same reason.

RATING SENSITIVITIES - SUPPORT RATING, SRFs and IDRs

On the downside, NCG's IDRs, SR and SRF are sensitive to a
downgrade of the Spanish sovereign rating or to any change in
Fitch's assumptions around the level of support available to the
bank, and in the near term, one of the alternative orderly
resolution scenarios arising.

On the upside, NCG's IDR could ultimately be affirmed or upgraded
were the bank to be recapitalized and its VR upgraded to 'bb+' or
higher or if the bank were to be recapitalized and sold to a
higher-rated bank.

RATING SENSITIVITIES - VR

Upon the confirmation or execution of any recapitalization plan
(due by end-November 2012) Fitch would downgrade NCG's VR to 'f',
reflecting the bank's failure under Fitch's definitions. After
recapitalization, the agency will re-assess NCG's VR and upgrade
it to a level commensurate with its post-support credit profile.

The rating actions are as follows:

NCG:

  -- Long-term IDR: 'BB+' placed on RWN
  -- Short-term IDR: 'B' placed on RWN
  -- Viability Rating: affirmed at 'c'
  -- Support Rating: '3' placed on RWN
  -- Support Rating Floor: 'BB+' placed on RWN
  -- Senior unsecured debt long-term rating: 'BB+' placed on RWN
  -- Senior unsecured debt short-term rating and commercial
     paper: 'B' placed on RWN
  -- Subordinated lower tier 2 debt: downgraded to 'C' from 'CC'
  -- Subordinated upper tier 2 debt: affirmed at 'C'
  -- Preferred stock: affirmed at 'C'
  -- State-guaranteed debt: affirmed at 'BBB'


* SPAIN: Moody's Says Covered Bond Issuers' Pools Vulnerable
------------------------------------------------------------
Spanish covered bond issuers report loan-to-value (LTV) ratios
that do not capture protection erosion, says Moody's Investors
Service in a new Special Comment published on Oct. 10. The
issuers' reported LTV ratios are based on original appraisal
valuations and therefore, these LTVs do not reflect the sharp
house price declines in Spanish house prices since 2008.

The new report, "Spanish Covered Bonds: Under-Reporting of
Negative Equity Mortgages Understates Mortgage Pool Credit Risk"
is now available on www.moodys.com. Moody's subscribers can
access this report via the link provided at the end of this press
release.

"We estimate that, after adjusting reported LTVs for house price
declines, more than 10% of the mortgages backing Spanish covered
bonds are in negative equity with LTVs exceeding 100%; this is
more than double the percentage the Spanish banks have reported,"
explains Jose de Leon, a Moody's Senior Vice President and author
of the report.

To determine the extent to which house price declines have eroded
protection beyond that indicated by an unadjusted LTV, the report
shows the results of Moody's sensitivity analysis on the relevant
cover pools, assuming no issuer support. Moody's projected
expected losses stemming exclusively from credit risk at
different borrower default rates and house price projections for
a sample from the mortgage cover pools backing the covered bonds
that Moody's rates.

"Our study shows that adjusting LTVs is necessary to project the
expected losses that credit risk causes. According to our central
scenario, around 24% of mortgages would be in negative equity if
prices were to fall another 20% in the next 18 months", adds Mr
de Leon. "The 20% drop implies a cumulative drop in house prices
of around 38% from Q1 2008 to end-2013".

Moody's says that credit losses on cover pools would almost
triple, and over-collateralization ratios would have to increase
by 43% for investors to avoid suffering losses if an issuing bank
cannot support its bonds, assuming the default rate
simultaneously increases to 20% from the current estimate of 10%
for mortgage assets. The estimates are based on Bank of Spain
data as of end July 2012 and Moody's own calculations based on
the analyzed cover pools (including both residential and
commercial mortgage loans).

Moody's says that when rating transactions, it adjusts the
reported LTVs to current market values and further stresses
changes in house prices. Moody's conclusions in this report will
therefore not have any impact on covered bond ratings, because
they already reflect the effect of negative equity on the
relevant loans.



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


CREDIT SUISSE: Fitch Affirms Rating on Tier 1 Notes at 'BB+'
------------------------------------------------------------
Fitch Ratings has affirmed Credit Suisse AG's Long-term Issuer
Default Rating at 'A' with a Stable Outlook and Short-term IDR at
'F1'.  The agency has also affirmed the bank's Viability Rating
(VR) at 'a', Support Rating at '1' and Support Rating Floor (SRF)
at 'A'.  At the same time, Fitch affirmed the ratings of Credit
Suisse's subsidiaries and holding company and of its issues.

The rating actions on Credit Suisse have been taken in
conjunction with Fitch's Global Trading and Universal Bank (GTUB)
periodic review.  Fitch's outlook for the industry is stable.
Positive rating drivers include improved liquidity, funding,
capitalization and more streamlined businesses, all partly driven
by regulation.  Offsetting these positive drivers are substantial
earnings pressure, regulatory uncertainty and heightened legal
and operational risk.

Rating Action Rationale

The affirmation of Credit Suisse's VR and IDR reflects the bank's
operations as a global investment bank and wealth manager with a
solid domestic retail and commercial banking franchise.  Credit
Suisse raised new capital in H212, which together with aggressive
reduction of risk-weighted assets (RWA), resulted in stronger
capitalization.  Its Fitch core capital ratio and regulatory
capital ratios measured under Basel III RWA are now in line with
its peers.

Fitch expects the bank to continue to concentrate on its core
segments in investment banking, which will continue to be the
group's main risk centre.  The group has reduced various market
risk metrics, and Fitch expects the investment bank's earnings to
show less volatility, after Q411 losses in the investment bank
that partly reflected its reduction in inventory and risk
positions.  Nevertheless, the agency considers that investment
banking activities give rise to material market and operational
risks, which are captured in Credit Suisse's VR.

The affirmation of Credit Suisse's Support Rating and SRF is
based on Fitch's view that the probability of support from the
Swiss authorities for Credit Suisse, if required, remains
extremely likely due to the bank's systemic importance for the
Swiss financial sector and the Swiss economy as a whole.

RATING DRIVERS AND SENSITIVITIES - IDRS, VR AND SENIOR DEBT

Credit Suisse's IDRs, its Stable Outlook and senior debt rating
are driven by its VR, which is based on Credit Suisse's good
global wealth management franchise and its significant market
share in global investment banking, as well as its retail and
commercial banking presence in Switzerland.  The VR also reflects
Credit Suisse's good track record in risk management, strong
liquidity and improved capitalization following the capital
measures announced in July 2012.

Fitch expects Credit Suisse to maintain a significant presence in
investment banking, and the agency's view of risk in this
industry is a negative rating driver.  However, the bank has a
good track record in managing the related risks, which along with
its strong global wealth management and domestic banking
franchises, places the VR in the 'a' category.  Fitch views
positively the reduced market risk exposure in the investment
bank, where Basel III RWA declined by about 38% between end-June
2011 and end-June 2012.

The aggressive RWA reduction resulted in losses in the investment
bank in Q411, but Fitch expects revenue volatility in the segment
to have fallen as a result.  Credit Suisse's VR is sensitive to
Fitch's assumptions on the bank's risk appetite in the investment
bank and would come under pressure if Credit Suisse materially
increased its risk taking in this segment or if it was unable to
maintain earnings volatility at a moderate level.

Credit Suisse's VR reflects Fitch's expectation that the bank
will maintain strong capital ratios. Swiss regulations will
require Credit Suisse to operate with a minimum 10% core capital
ratio under Basel III by 2019.  In addition, the bank will have
to hold 9% of loss-absorbing capital, which can be in the form of
contingent convertible instruments.

In July 2012, the bank announced measures to strengthen its
capital ratios, including the issuance of CHF3.8bn mandatory
convertible notes that will convert into common equity in March
2013.  As a result, Credit Suisse estimates a common equity tier
1 (CET1) ratio of 8.6% at end-2012, which places it in line with
most of its GTUB peers.  The increase in equity will also reduce
balance sheet leverage, although it remains some of the highest
among its peers.  Fitch expects the bank to increasingly manage
its balance sheet size, which should result in an improved
leverage ratio.  The generally good quality of assets and the
group's strong funding mitigates the high leverage, although
Fitch still considers this a negative rating driver for the bank
relative to most of its peers.

In addition to its CET1 capital, the bank has about CHF4.3bn
contingent convertible notes, which convert into common equity if
the group's CET1 ratio falls below 7%. Fitch considers this
buffer positive for the bank's VR as it provides further
protection for senior creditors.  Failure to reach and maintain
strong capital ratios would put pressure on Credit Suisse's VR.

The VR is also based on Credit Suisse's strong global wealth
management operations, which provide the bank with a more stable
source of earnings, although earnings in the segment are to some
extent driven by clients' risk appetite and transaction volumes.
With assets under management in the private bank of about
CHF989bn at end-June 2012, Credit Suisse is one the world's
largest wealth managers.  The bank's VR is sensitive to any
material and structural changes in the size of its wealth
management operations.

Fitch considers Credit Suisse's liquidity strong as it benefits
from a large and historically stable customer funding base, and
the bank estimates a net stable funding ratio of above 100% at
end-June 2012.  Liquidity is managed centrally, and Credit Suisse
maintains a large pool of liquid assets, partly driven by
stringent Swiss regulatory requirements.  At end-June 2012, the
bank reported CHF146bn of cash, securities accepted under central
bank facilities and other liquid securities.

RATING DRIVERS AND SENSITIVITIES - SUPPORT RATING AND SRF

The Support Rating and SRF are sensitive to a change in Fitch's
assumptions around the availability of sovereign support for the
bank.  In this context, Fitch is paying close attention to
ongoing policy discussions around bank support and 'bail in'.  An
upgrade of Credit Suisse's SRF is unlikely given Fitch's
expectation of diminishing sovereign support for banks in
Switzerland and globally.

Switzerland has made significant progress in implementing
specific legislation for the country's two largest banks (Credit
Suisse and UBS AG), which should ultimately facilitate bank
resolution and will eventually result in declining sovereign
support for Credit Suisse.  However, Fitch expects that this will
be a gradual and lengthy process, and the agency will take
corresponding rating actions when and if deemed appropriate.

Credit Suisse's Long-term IDR is at its SRF, but if the SRF was
downgraded, the IDRs would only be downgraded if the VR was below
its current 'a' level.

SUBORDINATED DEBT AND OTHER HYBRID SECURITIES

Subordinated debt and other hybrid capital issued by Credit
Suisse, Credit Suisse Group AG and by various issuing vehicles
are all notched down from the VRs of Credit Suisse or Credit
Suisse Group AG in accordance with Fitch's assessment of each
instrument's respective non-performance and relative loss
severity risk profiles, which vary considerably.  Their ratings
are primarily sensitive to any change in the VRs of Credit Suisse
or Credit Suisse Group AG.

HOLDING COMPANY RATING DRIVERS AND SENSITIVITIES

Credit Suisse Group AG's IDRs and VR are equalized with those of
Credit Suisse and reflect its role as the bank holding company
and the modest double leverage of 102% at end-2011 at holding
company level.

Credit Suisse Group AG's Support Rating and SRF reflect Fitch's
view that support from the Swiss authorities for the holding
company is possible, but cannot be relied on.  As Credit Suisse
AG's SRF is 'No Floor', the holding company's Long-term IDR is
driven purely by its VR and is therefore primarily sensitive to
the same drivers as Credit Suisse's VR.

SUBSIDIARY AND AFFILIATED COMPANY RATING DRIVERS AND
SENSITIVITIES

Credit Suisse International is a UK-based wholly-owned subsidiary
of Credit Suisse Group AG, and Credit Suisse (USA) Inc. (CSUSA)
is the group's main US-based broker-dealer.  Their IDRs are based
on support from their parent and are therefore equalized with
Credit Suisse's to reflect their core functions within the group
as major operating entities in the investment banking business.

Credit Suisse International is incorporated as an unlimited
liability company, which underpins Fitch's view that there is an
extremely high probability that it would receive support from its
parent if needed.  In H112, Credit Suisse International
restructured its capital base, redeeming subordinated debt placed
with its parent with participating shares placed with the parent,
thereby improving the quality of its capital.

CSUSA's parent companies (Credit Suisse and Credit Suisse Group
AG) in 2007 issued full, unconditional and several guarantees for
the firm's outstanding SEC registered debt securities, which in
Fitch's opinion demonstrate the role of the subsidiary and the
extremely high probability that the firm would be supported if
needed.

The rating actions are as follows:

Credit Suisse:

  -- Long-term IDR: affirmed at 'A', Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Viability Rating: affirmed at 'a'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A'
  -- Senior unsecured debt (including program ratings): affirmed
     at 'A'/'F1'
  -- Senior market-linked notes: affirmed at 'Aemr'
  -- Subordinated lower Tier 2 notes: affirmed at 'A-'
  -- Tier 1 notes and preferred securities: affirmed at 'BBB-'
  -- The rating actions have no impact on the ratings of the
     outstanding covered bonds issued by Credit Suisse

Credit Suisse Group AG

  -- Long-term IDR: affirmed at 'A', Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Viability Rating: affirmed at 'a'
  -- Support Rating: affirmed at '5'
  -- Support Rating Floor: affirmed at 'No Floor'
  -- Senior unsecured debt (including program ratings): affirmed
     at 'A'/'F1'
  -- Senior market-linked notes: affirmed at 'Aemr'
  -- Subordinated notes: affirmed at 'A-'
  -- Preferred stock (ISIN XS0148995888): affirmed at 'BBB'
  -- Preferred stock (ISIN XS0112553291 and JPY30.bn issue):
     affirmed at 'BBB-'

Credit Suisse International:

  -- Long-term IDR: affirmed at 'A', Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Support Rating: affirmed at '1'
  -- Senior unsecured debt (including debt issuance and CP
     program ratings): affirmed at 'A'/'F1'
  -- Dated subordinated notes: affirmed at 'A-'
  -- Perpetual subordinated notes: affirmed at 'BBB'

Credit Suisse (USA) Inc.:

  -- Long-term IDR: affirmed at 'A', Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Support Rating: affirmed at '1'
  -- Senior unsecured debt (including program ratings): affirmed
     at 'A'
  -- Commercial paper program: affirmed at 'F1'
  -- Subordinated notes: affirmed at 'A-'

Credit Suisse NY (branch):

  -- Long-term IDR: affirmed at 'A', Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Senior unsecured debt (including program ratings): affirmed
     at 'A'
  -- Commercial paper program: affirmed at 'F1'
  -- Senior market-linked notes: affirmed at 'Aemr'

Claudius Limited:

  -- Preferred securities: affirmed at 'BB+'

Credit Suisse Group (Guernsey) I Limited

  -- Tier 2 Contingent Notes: affirmed at 'BBB-'

Credit Suisse Group (Guernsey) II Limited

  -- Tier 1 Buffer Capital Perpetual Notes: affirmed at 'BB+'

Credit Suisse Group (Guernsey) IV Limited

  -- Tier 2 Contingent Notes: affirmed at 'BBB-'



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


ARCELIK AS: Fitch Affirms 'BB+' Long-Term Issuer Default Ratings
----------------------------------------------------------------
Fitch Ratings has affirmed Arcelik A.S.'s (Arcelik) Long-term
foreign and local currency Issuer Default Ratings (IDR) at 'BB+'
and National Long-term rating at 'AA-(tur)' The Outlook is
Stable.
The rating affirmation reflects Fitch's expectations that
profitability and free cash flow (FCF) will rebound in 2013,
following an erosion of the EBITDA margin to 10% in H112 from
10.6% in 2011 and 11.7% in 2010, and further negative FCF.
Fitch's current base case projects a rebound in EBITDA margin to
just less than 11% and positive FCF in 2013.  A lower or slower
improvement in profitability and cash generation in 2013 could
put renewed pressure on the ratings.

The ratings are supported by Arcelik's leading position in its
domestic market, its proven capability to grow export volumes and
a broadly stable financial profile.  Market share gains in
Europe, mainly due to European customers trading down in the
current difficult economic conditions, has supported Arcelik's
revenue growth in H112.  The majority of Arcelik's production is
based in low-cost locations such as Turkey, Romania, Russia and
South Africa, which allows the company to benefit from lower
costs compared to its EU based competitors (mainly from labour)
and its Asian competitors in terms of transportation costs due to
its proximity to the EU.

Arcelik's revenue grew 39% in H112, supported by all segments, as
well as the contribution from the full consolidation of Defy
acquired in Q411.  Excluding the effects of the Defy acquisition
and currency effect, sales jumped 27% organically.  This strong
growth prompted a significant working capital outflow and the
company is lagging behind its working capital target of 35% at
end-2012 (38.7% at end-June 2012).  As a result, FCF was negative
in H112, although Fitch expects FCF to improve and be positive in
H212 and beyond.

Despite higher than expected revenue growth, H112 EBITDA margin
were lower than historical levels at 9.9%.  Fitch believes this
deterioration is mainly because of persistently high raw material
costs, and margin losses coming from international markets and
the increased share of the electronics business where margins are
typically lower compared to the white goods sector.  Fitch
believes that profitability will rise slightly in the medium term
as the volatility surrounding raw material prices lessens.
However, increasing sales from international markets is likely to
continue putting pressure on earnings margins.

Debt increased slightly to TRY3.6 billion at end-H112 from 2011
YE levels of TRY3.1bn, mainly due to continuous working capital
needs.  This pushed the net debt/EBITDA ratio up to 2.5x but
Fitch expects some de-leveraging in 2013 as the company improves
its working capital management and its FCF generation ability.

Arcelik's reported leverage is negatively impacted by its higher
than average working capital needs, as a significant portion of
durable goods are sold on credit in Turkey, and this is partly
financed by Arcelik.  Given that Arcelik has historically seen
few losses on its trade receivables, Fitch adjusts Arcelik's debt
by netting off the debt portion of trade receivables above 60
days of revenues (approximately TRY1.7bn at end-H112) to enable a
more accurate peer comparison.  On this basis, Arcelik's adjusted
gross debt/EBITDA ratio was 2.0x at end-H112 (from 1.6x at end-
2011) and the adjusted FFO gross leverage was 2.2x.



=============
U K R A I N E
=============


MHP SA: Fitch Affirms 'B' Long-Term Issuer Default Ratings
----------------------------------------------------------
Fitch Ratings has affirmed Ukraine-based poultry and agricultural
producer MHP S.A.'s (MHP) Long-term foreign currency Issuer
Default Rating (IDR) at 'B' with a Stable Outlook.  The rating is
capped by Ukraine's Country Ceiling of 'B'. Fitch has also
affirmed the company's Long-term local currency IDR at 'B+' with
a Stable Outlook.  The senior unsecured rating applicable to
MHP's guaranteed bonds has been affirmed at 'B' with a Recovery
Rating of 'RR4'.

The affirmation reflects MHP's strong operating and financial
performance, which exceeded Fitch's expectations in 2011 and so
far in 2012.  The ratings also factor in the expectation of solid
credit metrics through to 2014 as capex will reduce drastically
from next year once the first stage of the Vinnitsa project comes
on stream in early 2013 adding 50,000 tonnes of chicken meat/year
of the planned 220,000 tonnes expansion by 2015.

MHP continues to benefit from strong vertical integration into
farming and fodder production.  However, its profile remains
constrained by its operational focus on one source of protein
(poultry) and by geography.  Lack of diversification together
with the currency mismatch between profits (mainly in UAH) and
debt (mainly in USD) translates into a higher risk profile
relative to companies of the sector in more developed markets.
The increasing share of exports, both poultry and sunflower oil,
partially mitigates any FX mismatch issues.

EBIT margin (excluding VAT refunds and other government grants
and before IAS41 gains) improved by 160bp to 17.3% in 2011, which
is high relative to other poultry producers that are not
integrated into farming, especially in North America and Brazil
(in the mid-to-high single digits).  MHP's strong profitability
is aided by growing meat consumption -- poultry is the cheapest
available choice and accounts for the majority of the increase in
consumption -- its high market share domestically and strong
pricing power.  Following an average increase of 28% for chicken
meat prices in H112 relative to H111, clearly outpacing the rise
in production costs, some of the latest profit gains may unwind
as high grain and feed prices will likely negatively affect
margins in 2013.  MHP will likely still record healthy
profitability under sales to external parties in its grain-
growing business.

Under a hypothetical sharp depreciation of the hryvnia, Fitch
estimates that MHP's FFO adjusted leverage would be marginally
impacted.  This is mitigated by the relatively high and rising
share of exports (11% of total sales volume of poultry and
sunflower oil) altogether representing USD400m-USD450m in annual
foreign-currency receipts, compared with very modest levels in
2008, the correlation between the price of chicken in the
Ukrainian market and the currency rate and the planned reduction
in capex for 2013.

Fitch expects positive free cash flow from 2013, with the FCF
margin averaging 9% between 2013 and 2015.  These should result
in a sustained reduction in FFO-adjusted net leverage from an
expected level of above 2.5x in 2012, towards 1.6x by 2015 and
healthy interest cover, measured as FFO fixed charge cover, above
5x, despite the assumption of selective acquisitions (mainly land
bank) and opportunistic share buy-backs.  In Fitch's view, this
represents a reasonable level of refinancing risk for MHP's
existing Eurobond due in 2015. These credit metrics place MHP
strongly in the 'B' rating category.

What Could Trigger A Rating Action?

Positive: future developments that may, individually or
collectively, lead to positive rating action on the local
currency IDR include:

  -- Greater business diversification and/or scale (the latter
     boosted by a stronger and sustained export presence)

  -- Evidence of sustained positive FCF

  -- FFO adjusted net leverage consistently below 2x

An upgrade of the foreign currency IDR would be possible only if
the Country Ceiling for Ukraine was upgraded (currently 'B').

Negative: future developments that may, individually or
collectively, lead to negative rating action on the local
currency IDR include:

  -- FFO adjusted net leverage rising above 2.5x due to sustained
     operational underperformance, aggressive capex plans or
     share buy-backs, or prompted by a sharper than expected
     depreciation of the hryvnia

  -- FFO fixed charge cover weakening below 4x

The foreign currency IDR would also come under pressure in the
event of substantial weakening in the foreign-currency interest
cover ratio (measured by exports to total cash interest in
foreign currency) below 3x.

Fitch has also affirmed MHP's subsidiary OJSC Myronivsky
Hliboproduct, as follows:

  -- Long-term foreign currency IDR: affirmed at 'B'; Stable
     Outlook

  -- Long-term local currency IDR: affirmed at 'B+'; Stable
     Outlook

  -- National Long-term rating: affirmed at 'AA+(ukr)'; Stable
     Outlook



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


BARCLAYS BANK: Fitch Affirms 'BB+' Rating on Preference Shares
--------------------------------------------------------------
Fitch Ratings has affirmed Barclays Bank plc's (Barclays Bank)
Long-term Issuer Default Rating (IDR) at 'A' with a Stable
Outlook and Short-term IDR at 'F1'.  At the same time, the agency
has affirmed the bank's 'a' Viability Rating (VR), '1' Support
Rating and 'A' Support Rating Floor (SRF).  The agency has also
affirmed the ratings of Barclays Bank's parent, Barclays plc and
all issue ratings.

The rating actions have been taken in conjunction with Fitch's
Global Trading and Universal Bank (GTUB) periodic review.
Fitch's outlook for the sector is stable.  Positive rating
drivers include improved liquidity, funding, capitalization and
more streamlined businesses, all partly driven by regulation.
Offsetting these positive drivers are substantial earnings
pressure, regulatory uncertainty and heightened legal and
operational risks.

The affirmation of Barclays Bank's VR and IDRs reflect these
themes, as well as the stable risk profile of its large and core
UK retail banking and Barclaycard operations.

RATING DRIVERS AND SENSITIVITIES - VR, IDRS AND SENIOR DEBT

Barclays Bank's IDRs are driven by its VR, which is based on the
bank's strong franchises across diversified businesses, its
generally good track record in managing credit and market risk
effectively, strong liquidity management and Fitch's expectation
that the bank will maintain sound capital ratios that are in line
with its global peers.  The VR also reflects market risk exposure
through its investment banking operations and the exposure to
material litigation risk.  Reputation risk is currently
considered high and a clear near-term priority for the bank's new
management team.

Fitch expects Barclays to continue to operate as a global
universal bank with material investment banking operations.  The
bank's newly appointed CEO launched a full review of the bank's
businesses, and Fitch expects this review to result in the
downscaling of some business areas, including for pure
reputational risk reasons.  However, at the same time, the new
CEO has already stated that he does not expect a breakup of the
bank or an exit from whole business lines.  Barclays Bank's
performance in H112 remained solid, despite a difficult operating
environment, and the bank benefits from good cost efficiency,
including in its investment banking business, compared to many
peers.

Barclays Bank's VR reflects Fitch's view that the bank has
generally managed credit and market risks effectively, especially
in its retail operations, and that it tightly controls risk
exposure.  The VR is sensitive to material changes in risk
appetite and would come under pressure if the bank materially
increased market risk exposure in its investment banking
operations, which Fitch currently does not expect.  As one of the
largest global investment banks, Barclays has strong market
shares in several key segments in fixed income and equities,
which potentially expose the bank to material market risk.  The
performance of the bank's investment banking activities
inevitably oscillates, but has remained more stable than at many
peers.

Barclays Bank's VR would also come under pressure if the bank's
asset quality, which has suffered particularly in its European
lending operations and is also starting to suffer in Africa,
deteriorates very significantly. Fitch believes that the bank's
good credit risk control has resulted in a loan book composition
that is more resilient to an economic downturn than at some of
its domestic and international peers.

Barclays Bank's exposure to GIIPS countries (the largest
exposures are residential mortgages in Italy and Spain) has
declined as the bank has actively reduced exposure and the
funding gaps of local operations in Spain, Portugal and Italy.
Nevertheless, at end-June 2012 the aggregate funding mismatch in
Spain ('BBB'/Negative), Portugal ('BB+'/Negative) and Italy ('A-
'/Negative) was material at GBP18bn, of which GBP11.9bn related
to Italy.  This gives rise to potential redenomination risk in a
very extreme scenario, but Fitch expects the funding mismatch to
be reduced further.

Fitch considers Barclays Bank's liquidity profile to be a
relative strength. Its large end-June 2012 liquidity pool of
GBP170bn, of which GBP124bn was held in cash and deposits with
central banks, is of high quality and amply covers GBP101bn of
short-term unsecured wholesale funding due within one year.
Barclays Bank's VR is sensitive to a deterioration of the bank's
funding and liquidity, which Fitch currently does not expect.

Barclays Bank's VR reflects Fitch's expectation that it will
maintain sound capitalization in the face of regulatory pressure.
The bank has estimated a 'look-through' Basel III core Tier 1
(CT1) ratio at the Barclays plc level of around 8.6% for January
2013, which would be in line with estimates for its peers, and
Fitch expects Barclays Bank to continue to strengthen its capital
ratios over the coming years.

As a retail and globally operating investment bank, Barclays Bank
is exposed to material litigation, regulatory and operational
risk, and charges for customer redress and regulatory fines in
2011 and H112 were significant.  Fitch expects that these risks
will remain higher than in the past, but that the related costs
will be absorbable through operating profit.  Barclays Bank's VR
would come under pressure if the probability of material losses
related to these risks increased.

Upward momentum for Barclays Bank's VR and IDR would either
require a material scaling back of its investment banking
ambition, which Fitch considers unlikely, or could arise as a
consequence of continuing further reduction in risk appetite and
exposure, combined with improvements in the group's operating
environment and profitability and further progress in
strengthening capitalization.

As Barclays Bank's VR and SRF are at the same level, a downgrade
of the VR would only result in a downgrade of its Long-term IDR
if the SRF was also lowered.

RATING DRIVERS AND SENSITIVITIES - SUPPORT RATING AND SUPPORT
RATING FLOOR

Barclays Bank's Support Rating and SRF reflect Fitch's
expectation that the UK authorities' propensity to provide
support for the large and systemically important banks will
remain high in the medium term.  Fitch expects support for banks
in the UK and other European countries to decline over time,
which would result in lower Support Ratings and SRFs.  Barclays
Bank's Support Rating and SRF are also sensitive to a weakening
of the UK authorities' ability to provide support and therefore
to the UK's creditworthiness.

GOVERNMENT GUARANTEED DEBT, SUBORDINATED DEBT AND OTHER HYBRID
SECURITIES

The 'AAA'/'F1+' debt and program rating assigned to debt
guaranteed by the UK government is based on the UK's sovereign
rating and reflects Fitch's view that the UK government would
ensure timely payment on the liabilities guaranteed by the
government.  The ratings are sensitive to any change in the UK's
sovereign rating.

Subordinated debt and other hybrid capital issued by Barclays are
all notched down from the VR of Barclays in accordance with
Fitch's assessment of each instrument's respective non-
performance and relative loss severity risk profiles, which vary
considerably. Their ratings are primarily sensitive to any change
in the VR of Barclays Bank.

HOLDING COMPANY RATING DRIVERS AND SENSITIVITIES

Barclays plc's VR and IDRs are equalized with those of Barclays
Bank and reflect the absence of any double leverage at the
holding company level.  Barclays plc's VR and Long-term IDR is
sensitive to any change in Barclay Bank's VR.  Barclays plc's
Support Rating and SRF reflect Fitch's view that support from the
UK sovereign for the holding company is possible, but cannot be
relied on.

The rating actions are as follows:

Barclays Bank

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Short-term IDR and short-term debt: affirmed at 'F1'
  -- Viability Rating: affirmed at 'a'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A'
  -- Senior unsecured debt: affirmed at 'A'
  -- Market linked securities: affirmed at 'Aemr'
  -- Government guaranteed senior long-term debt and programme:
     affirmed at 'AAA'
  -- Guaranteed senior short-term debt and programme: affirmed at
     'F1+'
  -- Lower Tier 2 debt: affirmed at 'A-'
  -- Upper Tier 2 debt: affirmed at 'BBB'
  -- Preference shares with no constraints on coupon omission:
     affirmed at 'BB+'
  -- Other hybrids: affirmed at 'BBB-'

The rating actions have no impact on the ratings of the
outstanding covered bonds issued by Barclays Bank

Barclays plc (Barclays's holding company parent)

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Short-term IDR: affirmed at 'F1'
  -- Viability Rating: affirmed at 'a'
  -- Support Rating: affirmed at '5'
  -- Support Rating Floor: affirmed at 'No Floor'

Barclays US CCP Funding LLC

  -- US Repo Notes Programme: affirmed at 'F1'


CLARIS LIMITED: Moody's Cuts Rating on Series 96/2007 to 'B2'
-------------------------------------------------------------
Moody's Investors Service took the following rating actions on
the notes issued by Claris Limited.

Issuer: Claris Limited

    Series 104/2007 Tranche 1 EUR 10,000,000 Sonoma Valley 2007-3
    Synthetic CDO of CMBS Variable Notes due 2049-1 Notes,
    Downgraded to Ba2 (sf); previously on Feb 11, 2011 Downgraded
    to Baa2 (sf)

    Series 105/2007 Tranche 1 USD 31,500,000 Sonoma Valley 2007-3
    Synthetic CDO of CMBS Variable Notes due 2049-2 Notes,
    Downgraded to Ba2 (sf); previously on Feb 11, 2011 Downgraded
    to Baa2 (sf)

    Series 106/2007 Tranche 1 USD 15,000,000 Sonoma Valley 2007-3
    Synthetic CDO of CMBS Variable Notes due 2049-3 Notes,
    Downgraded to B1 (sf); previously on Feb 11, 2011 Downgraded
    to Baa3 (sf)

    Series 96/2007 Tranche 1 USD 10,000,000 Sonoma Valley 2007-3
    Synthetic CDO of CMBS Variable Notes due 2037 Notes,
    Downgraded to B2 (sf); previously on Feb 11, 2011 Downgraded
    to Ba1 (sf)

Ratings Rationale

According to Moody's, the rating downgrade is the result of the
credit quality deterioration of the reference assets to which the
notes are exposed. Two assets in the pool were recently
downgraded by 5 and 4 notches respectively to the Baa range. The
pool consists of 27 equally weighted US CMBS assets. The 10-year
weighted average rating factor (WARF) of the pool is 45,
equivalent to A1. This compares to a 10-year WARF of 15 from the
previous rating action. The rated tranches are highly sensitive
to the credit quality of the worst rated assets in the pool
because of the thin credit enhancement and lumpiness of the pool.

Moody's also ran sensitivity analysis assuming various credit
quality evolution of the reference assets in the pool. In one
scenario, the worst rated asset was assumed to be rated in the Ba
range and in another, the 26% of Aa3 rated assets were assumed to
have been downgraded by 3 notches. The model output was within
two notches of the assigned ratings in each case.

The principal methodology used in these ratings was "Moody's
Approach to Rating SF CDOs" published in May 2012.

In rating this transaction, Moody's used CDOROM(TM) to model the
cash flows and determine the loss for each tranche. The Moody's
CDOROM(TM) is a Monte Carlo simulation which takes the Moody's
default probabilities as input. Each corporate reference entity
is modelled individually with a standard multi-factor model
incorporating intra- and inter-industry correlation. The
correlation structure is based on a Gaussian copula. In each
Monte Carlo scenario, defaults are simulated. Losses on the
portfolio are then derived, and allocated to the notes in reverse
order of priority to derive the loss on the notes issued by the
Issuer. By repeating this process and averaging over the number
of simulations, an estimate of the expected loss borne by the
notes is derived. As such, Moody's analysis encompasses the
assessment of stressed scenarios

In addition to the quantitative factors that are explicitly
modelled, qualitative factors are part of the rating committee
considerations. These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record,
and the potential for selection bias in the portfolio. All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.

Moody's notes that in arriving at its ratings of SF CDOs, there
exist a number of sources of uncertainty, operating both on a
macro level and on a transaction-specific level. Primary sources
of assumption uncertainty are the extent of the slowdown in
growth in the current macroeconomic environment and the
commercial and residential real estate property markets. While
commercial real estate property markets are gaining momentum, a
consistent upward trend will not be evident until the volume of
transactions increases, distressed properties are cleared from
the pipeline and job creation rebounds. Among the uncertainties
in the residential real estate property market are those
surrounding future housing prices, pace of residential mortgage
foreclosures, loan modification and refinancing, unemployment
rate and interest rates.

An additional source of performance uncertainty includes
portfolio non-granularity. The performance of the portfolio
depends on the credit conditions of a small number of obligors
that are equally weighted. Each obligor is 3.7% of the pool which
currently covers the entire subordination and most of each rated
tranche. If one experiences a jump to default, depending on
recoveries, the tranches could be completely wiped out by losses.


COOK AND BAKEWARE: Ceases Trading; 20 Workers Lose Jobs
-------------------------------------------------------
Henryk Zientek at Huddersfield Daily Examiner reports that
kitchenware shop Cook and Bakeware Company has ceased trading --
with the loss of up to 20 jobs.

The report relates that the independently-owned company has
closed a little over a year after it opened in premises at
Westgate.

Charles Brook, of Huddersfield-based business recovery firm Brook
Business Recovery, has been appointed liquidator of the company
at a meeting of creditors.

And efforts are under way to find a buyer for the business with a
view to the shop quickly re-opening.

Mr. Brook said the business had been hit by a combination of
factors, including slim margins and declining footfall.

Cook & Bakeware, which occupied the former Strawberry Fair
premises and employed up to 20 mainly part-time workers, sold
premium brand crockery and kitchenware.


COUNTRYLINER: In Administration, Contracts Terminated
-----------------------------------------------------
Matt Collison at guilfordpeople News reports that contracts with
bus service provider Countryliner have been terminated after the
company went into administration.

With effect from October 10, Surrey County Council (SCC) has
terminated all services the operator ran on behalf of the
authority, according to guilfordpeople News.

The report relates that Abellio Surrey has taken over the 10
Guildford to Merrow via Boxgrove Park service and Stagecoach has
taken over the 46 Aldershot to Guildford via Elstead route.  The
report relates that coaches Excetera is running the 24 Guildford
to Cranleigh via Birtley route and the 25 Guildford to Cranleigh
via Gomshall service.

The report relays that it is not yet confirmed which bus operator
is taking over the 479 Epsom to Guildford via Leatherhead
service, although SCC said Countryliner stated they will run the
service for October 10.


ESTIA MORTGAGE: Moody's Says Citibank Downgrade No Rating Impact
----------------------------------------------------------------
Moody's Investors Service has assessed that the downgrade of
Citibank N.A. London Branch (the Issuer Account Bank, the
"Counterparty") to (P)P-2 will not, in and of itself and at this
time, result in a downgrade or withdrawal of the current ratings
of the notes (the "Notes") issued by Estia Mortgage Finance II
PLC (the "Issuer"). Moody's opinion addresses only the credit
impact of the downgrade of the Counterparty at this time, and
Moody's is not expressing any opinion as to whether the downgrade
has, or could have, other non-credit related effects that may
have a detrimental impact on the interests of noteholders and/or
counterparties.

Estia Mortgage Finance II PLC Class A notes.

On June 21, 2012, Moody's downgraded the short term rating of the
Counterparty to (P)P-2 from (P)P-1. This resulted in a trigger
event under the account bank agreement. The agreement
contemplates several actions which the Counterparty may take
following a ratings event. The actions are (a) transferring the
issuer bank accounts to a third party; (b) obtaining a guarantee;
and (c) notifying Moody's in writing. On 19 September 2012, the
Counterparty opted for action (c) and notified Moody's.

Moody's has assessed the probability and impact of a default of
the Counterparty on the ability of the Issuer to meet its
obligations under the transaction. As the rating of the Notes are
Caa2(sf), below the current rating of the Counterparty, Moody's
has determined that the proposal to notify Moody's will not, in
and of itself and at this time, result in a downgrade or
withdrawal of the current ratings of the Notes.

The principal methodology used in this rating was Moody's
Approach to Rating RMBS in Europe, Middle East, and Africa
published in June 2012.

On August 21, 2012, Moody's released a Request for Comment
seeking market feedback on proposed adjustments to its modelling
assumptions. These adjustments are designed to account for the
impact of rapid and significant country credit deterioration on
structured finance transactions. If the adjusted approach is
implemented as proposed, the rating of the notes affected by the
rating action may be negatively affected. See "Approach to
Assessing the Impact of a Rapid Country Credit Deterioration on
Structured Finance Transactions",
(http://www.moodys.com/research/Approach-to-Assessing-the-Impact-
of-a-Rapid-Country-Credit--PBS_SF294880) for further details
regarding the implications of the proposed methodology changes on
Moody's ratings.

Moody's will continue to monitor the ratings of the transaction.
Any change in the ratings will be publicly disseminated by
Moody's through appropriate media.


HAWTHORNES OF NOTTINGHAM: KMPG Appointed as Liquidators
-------------------------------------------------------
Nottingham Post reports that Hawthornes of Nottingham has closed
with the loss of 55 jobs.  The family-owned firm, founded in
1895, appointed liquidators, blaming tough business conditions.

Chris Pole and Richard Philpott of KPMG's Nottingham office have
been appointed liquidators.

Nottingham Post relates that former chairman and chief executive
Chris Hawthorne said in a statement that: "It is with great
regret that the Hawthornes' directors report that KPMG have been
appointed liquidators of the company.  Hawthornes' performance
has been disappointing in the last eight years.

"Extensive restructuring has taken place since 2003. The
directors have worked very hard to reverse the downward trend and
especially so in the last few years.

"It has been an uphill fight with a poor British economy, prices
going down, more competition as machines have got faster,
customers delaying orders and the order intake being up and down
from month to month

"In the end, the directors decided that they could not continue."

Mr. Hawthorne, the major shareholder, added: "For me and the
Hawthorne family, it is a very sad end for our family company
founded in 1895. I feel very distressed for our staff, many of
whom are long serving and have worked very hard during this very
stressful period."

Hawthornes Of Nottingham Ltd -- http://www.hawthornes.co.uk/--
is a privately-owned printing business based in Nottingham,
United Kingdom.


LCP PROUDREED: Fitch Affirms 'BBsf' Rating on GBP9.2-Mil. Notes
---------------------------------------------------------------
Fitch Ratings has downgraded LCP Proudreed Plc's class A and B
commercial mortgage-backed floating rate notes due 2016 and
affirmed the two junior tranches as follows:

  -- GBP239.3 class A (XS0233008936) downgraded to 'AAsf' from
     'AAAsf'; Outlook Negative
  -- GBP32.2m class B (XS0233010163) downgraded to 'Asf' from
     'AAsf'; Outlook Negative
  -- GBP36.8m class C (XS0233010676) affirmed at 'BBBsf'; Outlook
     revised to Negative from Stable
  -- GBP9.2m class D (XS0233011054) affirmed at 'BBsf'; Outlook
     revised to Negative from Stable

Despite relatively stable collateral performance, Fitch's view of
the ongoing weakness in regional/secondary commercial real estate
market (assets of which largely secure the loans in this CMBS),
as evidenced by widening yield spreads and uncertainty over
future refinancing prospects, together with the top-heavy capital
structure, forms the basis for the downgrades and Negative
Outlooks.

The borrowers are covenanted to maintain a maximum loan-to-value
ratio (LTV) of 70% at each loan calculation date starting in
November 2012.  A covenant breach can be cured either by partial
loan (and by extension, note) redemption or by providing
additional collateral as security for the bondholders.  While
current reported LTVs are only slightly above the covenant level,
Fitch estimates the leverage to be well in excess of 80%.  With
new updated valuations due within 12 months, the borrowers'
commitment to meeting the LTV covenant is likely to be tested.

In the event of a covenant breach, and in lieu of borrower
intervention, excess rental income will be trapped and utilized
to reduce borrower indebtedness. Strong income performance
(interest cover is 3.84x and 3.57x for LCP and Proudreed,
respectively) still provides good potential for the loans to de-
lever to a level which will protect the class D notes against
losses.

The transaction is a securitization of two commercial mortgage
loans originated in the UK by HSBC Bank plc
('AA'/Negative/'F1+'), which closed in 21 December 2005.  The
loans are secured against 120 commercial properties located
across England, comprising retail (32%), industrial (34%), office
(3%), and shopping centre properties (31%).


NOVACEM: Enters Creditors' Voluntary Liquidation
------------------------------------------------
Cemnet.com reports that Novacem Limited said that it was
suspending operations and entering a creditors' voluntary
liquidation.

"Novacem has been tackling an enormous opportunity but
unfortunately we have not been able to raise the necessary
capital to continue developing the technology. We had built a
terrific team that had made significant progress, but now have no
option but to suspend operations and close the company. We have
valuable proprietary Technology and Intellectual Property and
hope to sell this to a company that can take it forward to full
development and commercialization," the report quots Novacem co-
founder and former Chairman Stuart Evans as saying.

James Money, a Partner at PKL (UK) LLP has been appointed
Liquidator and will be dealing with the sale of the Technology
and Intellectual Property, Cemnet.com relates.  Stuart Evans is
assisting him in the sale process, the report notes.

Novacem Limited is a carbon negative cement company based in
London, United Kingdom.


RAC FINANCE: S&P Affirms 'B+' Corp. Credit Rating; Outlook Stable
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its long-term
corporate credit rating on RAC Finance (Holdings) Ltd. (RAC) at
'B+'. The outlook is stable.

"In addition, we affirmed our 'B+' issue rating on the RAC's
existing senior secured debt facilities, in line with the
corporate credit rating on the group. We revised our recovery
rating on these facilities downward to '4' from '3', indicating
our expectation of average (30%-50%) recovery in an event of
payment default," S&P said.

"At the same time, we assigned our 'B+' issue rating to the RAC's
proposed new GBP260 million term loan C, subject to the group
raising the loan successfully. The recovery rating on the loan is
also '4'," S&P said.

"The affirmation follows the RAC's proposal to add a new GBP260
million term loan C facility to its capital structure. The
proceeds of this new facility, plus GBP30 million of cash on the
balance sheet, will be used to repay GBP290 million of existing
shareholder loans. The existing term loan B facility will remain
in place," S&P said.

"The affirmation reflects our view that the RAC is effectively
swapping a portion of its existing shareholder loans for bank
debt. As we already considered the existing shareholder loans as
debt under our criteria, the group's financial risk profile
remains in the 'highly leveraged' category, despite the change in
its capital structure. The remaining shareholder loans will
continue to accrue payment-in-kind interest at a rate of 12% per
year," S&P said.

"We continue to assess the group's business risk profile as
'fair,' reflecting its low-risk, membership-based, operating
model; national scale; and strong U.K. brand recognition. The
group has relatively limited exposure to macroeconomic cycles and
benefits from significant barriers to entry. The 'fair' business
risk profile also reflects the RAC's limited geographic
diversification, since it generates almost all its revenues in
the U.K.," S&P said.

"In our opinion, even taking a conservative view of future growth
prospects, the RAC should be able to maintain the financial
flexibility necessary to service its highly leveraged debt
structure. This reflects the group's solid operating track
record, positive free cash flow generation, and our view of the
stability of its individual membership business model. In
addition, we note an absence of near-term refinancing challenges,
provided that the group maintains adequate headroom under its
financial covenants," S&P said.

"We could lower the rating if the group failed to maintain
adjusted funds from operations to debt above 7% (adjusted for
leases and the shareholder loans)," S&P said.

"We see a positive rating action as unlikely in the near-to-
medium term, because the RAC has a highly leveraged capital
structure," S&P said.


RANGERS FC: Blasts Rumors on Possible Administration
----------------------------------------------------
Gavin Berry at Daily Record reports that Club 9 Sports Chief Jon
Pritchard has spoken of his fears for Rangers Football Club's
future as he outlined the reasons pal Bill Miller pulled out of
buying the club.

Mr. Pritchard, who continued to work with Miller even though the
Tennessee towing truck magnate had distanced himself from Club 9,
insisted in an article carried by financial magazine Forbes that
more insolvency issues could follow, according to Daily Record.

The report discloses that Mr. Pritchard detailed what must be
done to avert, what he believes to be another impending crisis.

"It may be unpopular and an affront to the personal sensibilities
of some but Rangers needs to learn to live within its means . . .
. It's time to cut the fat from every department and rebuild an
organization that values every pound and demands a return on all
expenses.  If Charles Green is not willing to face the fans,
explain the economics and risk the torrent of abuse in the short
term, Rangers will shortly be back in the same place," the report
quoted Mr. Pritchard as saying.

However, the report notes that Ibrox Chairman Malcolm Murray
blasted back at the claims and branded them "ill-informed
scaremongering."

The report relays that Mr. Murray said: "The last time Mr.
Pritchard had sight of any financial information about Rangers
was many months ago. His article is ill informed, misleading and
scaremongering . . . . There is no risk of the club going into
administration and any suggestion otherwise is scandalous."

As reported by the Troubled Company Reporter-Europe, BBC News
related that Rangers appointed administrators on Feb. 14, with
Her Majesty's Revenue and Customs pursuing an unpaid GBP9 million
tax bill accrued since owner Craig Whyte assumed control at Ibrox
last May.

                   About Rangers Football Club

Rangers Football Club PLC -- http://www.rangers.premiumtv.co.uk/
-- is a United Kingdom-based company engaged in the operation of
a professional football club.  The Company has launched its own
Internet television station, RANGERSTV.tv.  The station combines
the use of Internet television programming alongside traditional
Web-based services.  Services offered include the streaming of
home matches and on-demand streaming of domestic and European
games, which include dedicated pre-match, half-time and post-
match commentary.  The Company will produce dedicated news
magazine and feature programs, while the fans can also access a
library of classic European, Old Firm and Scottish Premier League
(SPL) action.  Its own dedicated television studio at Ibrox
provides onsite production, editing and encoding facilities to
produce content for distribution on all media platforms.


ROYAL BANK: Fitch Affirms 'BB+' Rating on Subordinated Debt
-----------------------------------------------------------
Fitch Ratings has affirmed The Royal Bank of Scotland Group's
(RBSG) and The Royal Bank of Scotland Plc's (RBS) Long-term
Issuer Default Ratings (IDR) at 'A', Short-term IDRs at 'F1',
Support Ratings at '1' and Support Rating Floors (SRF) at 'A'.
The Outlooks are Stable.  The banks' Viability Ratings (VR) have
also been affirmed at 'bbb'.

The rating actions on RBSG and RBS were taken in conjunction with
Fitch's Global Trading and Universal Bank (GTUB) periodic review.
Fitch's outlook for the sector is stable on balance.  The
positive rating drivers include improved liquidity, funding,
capitalization and more streamlined businesses, all partly driven
by regulation.  Offsetting these positive drivers are substantial
earnings pressure, regulatory uncertainty and heightened legal
and operational risk.

While these themes are also valid for RBSG, Fitch notes that the
bank's investment banking ambition is becoming more focused as
the group continues its restructuring, de-risking and downsizing.
This should result in lower earnings volatility and less tail
risk over time.  As this progresses and 'non-core' assets reduce,
the group's business, earnings and risk profile (and hence VR)
will increasingly be dominated by its core and strong franchises
in retail, commercial and corporate banking.

RATING DRIVERS AND SENSITIVITIES - SUPPORT RATINGS, SRF, IDRs AND
SENIOR DEBT

RBS's and RBSG's IDRs, senior debt, Support Ratings and SRFs have
been affirmed because Fitch believes the group's systemic
importance to the UK still implies a strong probability of
support from the UK authorities if needed.  Although on a
weakening trend, Fitch expects the UK authorities' propensity to
support RBS to remain high while the bank continues its
restructuring, while UK and EU regulatory and legislative
measures designed to improve bank stability are phased in and
until measures designed to weaken the implicit support for banks,
at both a UK-specific and at an EU level, can be practically
implemented.

These ratings are sensitive to a change in Fitch's assumptions
around the ability or propensity of the UK government to provide
extraordinary support to RBS/RBSG if needed.

RATING DRIVERS AND SENSITIVITIES - VR

RBS's VR reflects its strong and profitable core UK retail and
commercial banking franchise, its sound liquidity and the
significant progress which has been made in improving the bank's
overall risk profile, notably in deleveraging the balance sheet,
reducing reliance on wholesale unsecured funding and embracing a
stronger risk culture.

Nonetheless, it also considers the risks (mostly credit)
associated with its much reduced but still sizable 'non-core'
assets, especially commercial real estate and Irish portfolios,
continuing weak overall profitability and residual concentration
risks on the asset side of the balance sheet.  Political,
litigation and reputational risks also act as a constraint.

Fitch believes that RBSG is well positioned to pursue its
strategic plan thanks to its strong core retail and commercial
franchises and strengthened governance structures.  Nonetheless,
de-risking and de-leveraging, as well as building up liquidity,
have had a negative impact on margins.  This has exacerbated the
pressure on profitability associated with the restructuring
process.  Bottom line profitability remains weak, even if
earnings in the 'core' bank - which will become more visible as
the non-core bank continues to wind down - are sound.

While capital ratios comfortably exceed regulatory requirements,
capitalization needs to be considered in the context of residual
concentration risks and a relatively high level of uncovered non-
performing loans (NPLs), which exposes the bank to further falls
in collateral values.  A return to sustainable profitability as
the non-core operations continue to wind down is likely to be the
most positive development for the bank's capital flexibility and
generation.

On balance, Fitch considers RBSG's VR to be capable of further
improvement over the medium-term. This would likely be driven by
a further reduction in credit and market risks and an improvement
in profitability whilst maintaining the group's strong franchise
and liquidity profile.

Downside risk to the bank's VR would most likely be a consequence
of adverse external factors as an increase in risk appetite is
improbable.  It would be most likely to arise due to a sharper
and more drawn-out than anticipated deterioration in the economic
and operating environment and the ensuing asset quality
deterioration the bank would face.  A particularly disruptive or
expensive and extended reputational or litigation event (the bank
is likely to be exposed to LIBOR-related fines and litigation)
could also create downside risks.

RBSG's VR and VR sensitivities are driven by the same
considerations that underpin the VR of its main banking
subsidiary, RBS, as well as the absence of any double leverage.

RATINGS DRIVERS AND SENSITIVITIES - SUBORDINATED AND HYBRID DEBT

Subordinated debt and other hybrid capital issued by RBSG and by
RBS, National Westminster Bank and Royal Bank of Scotland NV are
all notched down from the VRs of RBSG or RBS in accordance with
Fitch's assessment of each instrument's respective non-
performance and relative loss severity risk profiles, which vary
considerably. Their ratings are primarily sensitive to any change
in RBSG's or RBS's VRs.

RATINGS DRIVERS AND SENSITIVITIES - SUBSIDIARIES

Royal Bank of Scotland NV (RBS NV) is the former ABN Amro Bank
legal entity, much of whose business acquired by RBS is being
transferred to RBS plc's balance sheet.  Its IDRs are aligned
with those of RBS because of its high operational integration and
the extremely high likelihood it would be supported by RBS if
needed.  Most of its UK and European business has been
transferred or are in the process of being transferred to the UK
operations.  Fitch believes it cannot be meaningfully analyzed on
a standalone basis (it has no VR) and its IDRs are sensitive to
the same considerations that could affect RBS.

National Westminster Bank is a core subsidiary of RBS and, while
a separate legal entity, highly integrated with it operationally.
Fitch believes it cannot be meaningfully analyzed on a standalone
basis (it has no VR), that its overall risk profile is
indistinguishable from that of RBS and that it is hard to
countenance a default of one bank and not the other. Its IDRs are
thus driven by the same rating drivers and sensitivities as those
of RBS.

Royal Bank of Scotland International Limited (RBSI) provides core
offshore banking operations. RBSI's IDRs are the same as those of
its parent RBS, reflecting its ownership, the alignment of risk
management procedures and operating platforms with RBS, and the
close alignment of RBSI's activities with those of the RBS
Group's core UK bank.  In Fitch's opinion there is an extremely
strong likelihood of support being provided by RBS to RBSI should
it ever be required. Its IDRs are thus driven by the same rating
drivers and sensitivities as those of RBS.

RATING IMPLICATIONS - LEGISLATIVE CHANGE

The UK government's Q212 White Paper proposal to ring-fence UK
retail operations could, depending on the shape of
implementation, potentially have major implications for legal
entities' individual funding and risk profiles within the group
and create more rating differentiation between legal entities
within the group than is currently the case.  Uncertainty over
the ultimate implications and how they will be addressed by the
group means it is not yet something that Fitch has directly
factored into legal entity or debt class ratings.  Ratings
implications could be positive or negative, dependent on legal
entity activities, size/scope of operation and risk profiles, the
strength of ring-fences, risk mitigation, group relationships and
support etc.

The full list of rating actions is as follows:

RBSG

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Senior unsecured debt: affirmed at 'A'/'F1'
  -- Senior unsecured market linked securities: affirmed at
     'Aemr'
  -- Short-term IDR: affirmed at 'F1'
  -- Commercial paper and short-term debt: affirmed at 'F1'
  -- Viability Rating: affirmed at 'bbb'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A'
  -- Subordinated debt: affirmed at 'BB+'
  -- Innovative Tier 1 and Preferred stock: affirmed at 'B+'
  -- Other hybrids (USD1.2bn, US780097AH44; GBP200m XS0121856859;
  -- USD1bn US780097AE13 and USD300m US7800978790): affirmed at
     'BB-'

RBS

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Senior unsecured debt: affirmed at 'A'/'F1'
  -- Senior unsecured market linked securities: affirmed at
     'Aemr'
  -- Short-term IDR: affirmed at 'F1'
  -- Commercial paper and short-term debt: affirmed at 'F1'
  -- Viability Rating: affirmed at 'bbb'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A'
  -- Guaranteed senior long-term debt: affirmed at 'AAA'
  -- Subordinated Lower Tier 2 debt affirmed at 'BBB-'
  -- Subordinated Upper Tier 2 debt affirmed at 'BB'
  -- EUR1bn Dated Subordinated Debt, XS0201065496 affirmed at
     'BB+'

RBS NV

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Senior unsecured debt: affirmed at 'A'/'F1'
  -- Senior unsecured market linked securities: affirmed at
     'Aemr'
  -- Short-term IDR: affirmed at 'F1'
  -- Commercial paper: affirmed at 'F1'
  -- Support Rating: affirmed at '1'
  -- Subordinated debt: affirmed at 'BBB-'

RBSI

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Short-term IDR: affirmed at 'F1'

National Westminster Bank plc

  -- Long-term IDR: affirmed at 'A'; Outlook Stable
  -- Senior unsecured debt: affirmed at 'A'/'F1'
  -- Short-term IDR: affirmed at 'F1'
  -- Support Rating: affirmed at '1'
  -- Support Rating Floor: affirmed at 'A'
  -- Subordinated Lower Tier 2 debt: affirmed at 'BBB-'
  -- Subordinated Upper Tier 2 debt: affirmed at 'BB'


SKILLSFINDER UK: In Administration, Denies Northwood Claim
----------------------------------------------------------
Education Investor reports that Skillsfinder UK has gone into
administration and appointed insolvency administrators.

Tribal Group, to which the company was a subcontractor, posted an
announcement that "[it] is now in the process of finding
alternative support arrangements for learners affected by this
situation . . . . From the perspective of employers and learners,
Tribal remains absolutely committed to ensuring continuity of
support for each person or company involved."

Skillsfinder provided tutor and assessor support to Tribal's
contract with the Skills Funding Agency.

Meanwhile, the Swindon Advertiser, James Jennings, the managing
director of Northwood Environmental has gone into liquidation
with its management blaming Skillsfinder for its inability to pay
its staff.  The report relates that the management claimed
Skillsfinder owed Northwood Environment GBP215, 000.

The report discloses that Skillsfinder has denied the claim,
saying the dispute was over a much smaller figure.


STANDARD BANK: Moody's Affirms 'D/ba2' Ratings
----------------------------------------------
Moody's Investors Service has affirmed the ratings of Standard
Bank plc (SBP) (Baa2, D/ba2 negative) following the recent rating
action on the local and foreign currency deposit ratings of
Standard Bank of South Africa (SBSA), the largest operating
entity of the Standard Bank Group Limited (SBGL), which is also
the ultimate parent of SBP. The standalone Baseline Credit
Assessment (BCA) of SBSA was downgraded to baa1 from a3, leading
to a similar downgrade in its foreign-currency long-term deposit
rating to Baa1 from A3.

Ratings Rationale

Moody's assigns a very high probability of support from the group
(SBGL) to SBP given its core position as part of the group's
commercial and investment banking franchise. As a result, SBP's
Baa2 bank deposit and long term debt ratings continue to benefit
from three notches of uplift from its standalone credit
assessment of ba2.

What Could Change The Rating Up/Down

Since the creditors of SBP's parent company and support provider
SBGL are structurally subordinated to creditors of SBSA (the main
operating entity and primary source of strength within the
group), Moody's will likely maintain the notch differential
between the standalone ratings of SBSA and the long term ratings
of SBP. Consequently, any further downgrade of the standalone
ratings of SBSA will likely result in a downgrade by the same
number of notches of the deposit and senior long term ratings of
SBP.

A rating upgrade of SBP's debt ratings at this stage is unlikely
to stem from improving fundamentals of SBP, given the bank's
lower standalone BCA at ba2. This reduces the senior debt
ratings' sensitivity to an improvement of the standalone rating
profile of SBP.

SBP is a core part of SBGL's strategy which aims to have one
integrated business line across regions connecting Africa and
other selected emerging markets to each other.

The principal methodology used in this rating was Moody's
Consolidated Global Bank Rating Methodology published in June
2012.



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


* BOOK REVIEW: Legal Aspects of Health Care Reimbursement
---------------------------------------------------------
Authors:  Robert J. Buchanan, Ph.D., and James D. Minor, J.D.
Publisher: Beard Books
Softcover: 300 pages
List Price: $34.95
Review by Henry Berry

With Legal Aspects of Health Care Reimbursement, Buchanan, a
professor in the School of Public Health at Texas A&M, and Minor,
an attorney, have come up with an invaluable resource for lawyers
and anyone else seeking an introduction to the legal and social
issues related to Medicare and Medicaid.  The administrative
costs of Medicare and Medicaid reimbursement have been a heated
topic of debate among public officials and administrators of
provider healthcare organizations, especially health maintenance
organizations.  Although inflation and the use of costly medical
technology are key factors in the rise in Medicare and Medicaid
costs, some control can be gained through appropriate compliance,
using more efficient procedures and better detection of fraud.
This work is a major guide on how to go about doing this.
Though mostly a legal treatise, Legal Aspects of Health Care
Reimbursement, first published in 1985, also offers commentary
through legislative and regulatory analyses, thereby explaining
how healthcare reimbursement policies affect the solvency and
effectiveness of the Medicare and Medicaid programs.
In discussing how legislation and regulations affect the solvency
and effectiveness of government-provided healthcare, the authors
offer insight into the much-publicized and much-discussed issue
of
runaway healthcare costs.  Buchanan and Minor do not deny that
healthcare costs are out of control and are onerous for the
government and ruinous for many individuals.  But healthcare
reimbursement policies are not the cause of this, the authors
argue.  To make their case, they explain how the laws and
regulations in different areas of the Medicare and Medicaid
programs create processes that are largely invisible to the
public, but make the programs difficult to manage financially.
The processes are not well thought out nor subject to much
quality control, with the result that fraud is chronic and
considerable.

The areas of Medicare covered in the book are inpatient hospital
reimbursement, long-term care, hospice care, and end-stage renal
disease.  The areas of Medicaid covered are inpatient hospital
and long-term care plus abortion and family planning services.
For each of these areas, the authors discuss the conditions for
receiving reimbursement, the legislation and regulations
regarding reimbursement, the procedures for being reimbursed, the
major areas of reimbursement (for example, capital-related costs,
dietetic services, rental expenses); and court cases, including
appeals.  Reimbursement practices of selected states are covered.
For each of the major areas of interest, the chapters are
organized in a manner that is similar to that found in reference
books and professional journals for attorneys and accountants.
Laws and regulations are summarized and occasionally quoted with
expert background and commentary supplied by the authors.  With
regard to court cases and rulings pertaining to Medicare and
Medicaid, passages from court papers are quoted, references to
legal records are supplied, and analysis is provided. Though the
text delves into legal issues, it is accessible to administrators
and other lay readers who have an interest in the subject matter.
Clear chapter and subchapter titles, a table of cases following
the text, and a detailed index enable readers to use this work as
a reference.

The value of this book is reflected in the authors' ability to
distill great amounts of data down to one readable text.  It
condenses libraries of government and legal documents into a
single work.  Answers to questions of fundamental importance to
healthcare providers -- those dealing with qualifications,
compliance, reimbursable costs, and appeals -- can be found in
one place. Timely reimbursement depends on proper application of
the rules, which is necessary for a provider's sound financial
standing. But the authors specify other reasons for writing this
book, to wit: "Providers should have a general knowledge of the
law and should not rely on manuals and regulations exclusively."
By summarizing, commenting on, and citing cases relating to
principal provisions of Medicare and Medicaid, the authors
accomplish this objective.

The authors also cover the topic of fraud with respect to both
Medicare and Medicaid, offering both a legal treatment and
commentary.  At the end of each chapter is a section titled
"Outlook," which contains a discussion of government studies,
changes in healthcare policy, or other developments that could
affect reimbursement.  Although this work was published over two
decades ago, much of this discussion is still relevant today.
Finally, the book is a call for change.  The authors remark in
their closing paragraph: "Given the increasing for-profit
orientation of the major segments of the health care industry,
proprietary providers should be particularly responsive to new
efficiency incentives" in reimbursement.  In relation to this,
"policymakers [should] develop reimbursement methods that will
encourage providers to become more efficient."

Robert J. Buchanan is currently a professor in the Department of
Health Policy and Management in the School of Rural Public Health
at the Texas A&M University System Health Sciences Center.  James
D. Minor, a former law professor at the University of
Mississippi, has his own law practice.


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
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is compiled on the Friday prior to publication.  Prices reported
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information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
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affiliated with a TCR editor holds some position in the issuers'
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than US$3 per
share in public markets.  At first glance, this list may look
like the definitive compilation of stocks that are ideal to sell
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prices at which equity securities trade in public market are
determined by more than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Thursday's edition of the TCR. Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com

Each Friday's edition of the TCR includes a review about a book
of interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/booksto order any title today.


                            *********


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., Frederick, Maryland
USA.  Valerie U. Pascual, Marites O. Claro, Rousel Elaine T.
Fernandez, Joy A. Agravante, Ivy B. Magdadaro, Frauline S.
Abangan and Peter A. Chapman, Editors.

Copyright 2012.  All rights reserved.  ISSN 1529-2754.

This material is copyrighted and any commercial use, resale or
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Information contained herein is obtained from sources believed to
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