/raid1/www/Hosts/bankrupt/TCREUR_Public/190730.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

          Tuesday, July 30, 2019, Vol. 20, No. 151

                           Headlines



C R O A T I A

HELIOS FAROS: Valamar Riviera Takes Control of 23.61% Stake
ULJANIK: Delivers Luxury Cruise Ship to Malta-Based Client


C Z E C H   R E P U B L I C

SAZKA GROUP: S&P Puts 'BB-' ICR on Watch Neg. Ff. OPAP Tender Offer


G E R M A N Y

RODENSTOCK GMBH: Fitch Affirms B- LT IDR, Outlook Stable


G R E E C E

OPAP SA: S&P Places 'BB-' ICR on CreditWatch Neg.


I R E L A N D

AVARA SHANNON: High Court Enters Wind Up Order
BARINGS EURO 2019-1: Moody's Rates EUR8.8MM Cl. F Notes (P)B3(sf)


N E T H E R L A N D S

INTERXION HOLDING: S&P Raises LT ICR to 'BB' on Equity Issuance


N O R W A Y

SECTOR ALARM: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable


R U S S I A

CB ASSOTSIATSIYA: Put on Provisional Administration
FG BCS: S&P Raises LT ICR to 'B', Outlook Positive
KRASNODAR CITY: Moody's Alters Outlook on B1 Issuer Rating to Pos.
VOZROZHDENIE BANK: S&P Withdraws 'B+/B' Issuer Credit Ratings


S P A I N

DISTRIBUIDORA INTERNACIONAL: Moody's Confirms Caa1 CFR, Outlook Neg
DISTRIBUIDORA INTERNACIONAL: S&P Affirms 'CCC' LT ICR, Outlook Neg


T U R K E Y

ARTS LTD: Fitch Downgrades DPR Notes to BB+, Outlook Negative
ISTANBUL TAKAS: Fitch Downgrades LT IDR to BB-, Outlook Negative


U N I T E D   K I N G D O M

HARLAND & WOLFF: In Talks with Potential Buyers, Future Uncertain
NOVARI LIMITED: Jailed Restaurateur Banned After GBP1MM Tax Fraud
SELECT: Owes Creditors GBP53MM After Collapse
TOM HALL'S: Financial Difficulty Prompts Liquidation, Closure
WESTON ELECTRICAL: Cash Flow Issues Prompt Administration

WOODFORD EQUITY: Investors Unlikely to Access Cash Until December

                           - - - - -


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C R O A T I A
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HELIOS FAROS: Valamar Riviera Takes Control of 23.61% Stake
-----------------------------------------------------------
SeeNews reports that Croatian hotel operator Valamar Riviera said
it has taken control of a 23.61% stake in local peer Helios Faros
following recapitalization of bankrupt Helios.

Valamar said in a Zagreb bourse filing, with the completion of the
bankruptcy proceedings against Helios Faros on July 22, it has
gained full rights as 23.61%-owner of the Hvar-based company,
SeeNews relates.

In May, the bankruptcy administrator of Helios decided to increase
the capital of the troubled company via cash payments, SeeNews
recounts.

Valamar paid for and acquired its minority stake in Helios, while
pension insurance fund PBZ Croatia Osiguranje paid for a stake of
70.83% of Helios, Valamar, as cited by SeeNews, said without
disclosing the amount of their cash contributions.

The proceeds were used to repay Helios' debts to creditors,
creating the conditions for its exit from the bankruptcy
proceedings, SeeNews states.

Helios Faros went bankrupt in 2016 and a year later accepted the
recapitalization bid made by Valamar and PBZ Croatia Osiguranje,
SeeNews discloses.  Prior to the acceptance, Valamar and PBZ had
proposed to invest HRK650 million (US$98 million/EUR88 million) in
Helios Faros over six years, SeeNews notes.


ULJANIK: Delivers Luxury Cruise Ship to Malta-Based Client
----------------------------------------------------------
SeeNews reports that Croatia's shipyard Uljanik, which is going
through bankruptcy proceedings, said on July 26 it has delivered a
newly-built polar-class luxury cruise ship to its client,
Malta-based PEC Limited.

Uljanik said in a statement the ocean going ship can carry 237
passengers, SeeNews relates.

In May, a Croatian court launched bankruptcy proceedings against
Uljanik over the shipyard's overdue debts, SeeNews recounts.




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C Z E C H   R E P U B L I C
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SAZKA GROUP: S&P Puts 'BB-' ICR on Watch Neg. Ff. OPAP Tender Offer
-------------------------------------------------------------------
S&P Global Ratings placed its 'BB-' issuer credit rating on Czech
Republic-Based Sazka Group A.S. on CreditWatch with negative
implications.

The CreditWatch placement follows the announcement on July 8, 2019
that Sazka has launched a tender offer for OPAP's publicly traded
shares. The offer remains subject to approval from the Hellenic
Capital Markets Commission (HCMC). The transaction is an all cash
offer of EUR9.12 per share, representing EUR2.06 billion for 67% of
OPAP. Sazka currently holds an indirect stake of 33% in OPAP
through the intermediate holding company EMMA Delta, in which Sazka
has direct ownership of 75.5%.

S&P said "To date, we consolidate OPAP on a proportional basis in
our calculation of Sazka's credit metrics. If Sazka increased its
stake in OPAP to above 50% as part of this transaction, we would
then fully consolidate it, which would likely improve our view of
Sazka's business assessment.

"We understand that the HCMC has a couple of weeks to review the
offer. If it approves the offer, Sazka will proceed with the public
tender offer to existing shareholders. The raised debt amount will
depend on the final stake acquired by Sazka, and therefore the
rating is subject to the transaction outcome. However, we
anticipate that Sazka's credit metrics will weaken--its adjusted
debt-to-EBITDA ratio is currently at 3.0x-3.5x--and there is a
possibility that we could lower our rating on Sazka if it acquires
significant stakes through a debt-financed acquisition. We expect
to obtain further information regarding the potential acquisition
within the next one to two months.

"We expect to resolve the CreditWatch within the next three months,
upon completion of the potential acquisition and after assessing
Sazka's financial risk profile pro forma the transaction, with
emphasis on the ownership stake acquired and the subsequent amount
of debt raised.

"We would consider affirming the 'BB-' rating on Sazka and removing
it from CreditWatch negative if the pro forma credit metrics
support the current rating or if the takeover does not take
place."




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G E R M A N Y
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RODENSTOCK GMBH: Fitch Affirms B- LT IDR, Outlook Stable
--------------------------------------------------------
Fitch Ratings has assigned Rodenstock GmbH's seven-year term loan B
of EUR395 million and a six-and-a-half year EUR20 million revolving
credit facility a final senior secured loan rating of 'B'/'RR3'.
The assignment of the final rating follows a review of the loan
documentation being materially in line with the draft terms
originally presented to Fitch. The new facilities replace the
previous senior secured facilities, which have been repaid in
full.

Fitch has also affirmed European Optical Manufacturing Sarl's Long
Term Issuer Default Rating (IDR) at 'B-' and withdrawn the rating.
At the same time it has assigned Rodenstock Holding GmbH a
Long-Term IDR of 'B-' with Stable Outlook. This reflects the
alignment of the rated group of companies with the restricted group
under the new financing documentation.

The IDR of European Optical Manufacturing Sarl was withdrawn with
the following reason: Reorganisation of Rated Entity

KEY RATING DRIVERS

Refinancing Risk Addressed: The new capital structure addressed
Rodenstock's refinancing risk by extending debt maturities to June
2026. The loan documentation offers more flexibility with no
maintenance covenants, and the ability to raise permitted
additional debt subject to certain leverage thresholds. While this
potentially provides Rodenstock with more flexibility, it weakens
the debtholders' position.

High Leverage, Slow Deleveraging: Despite the lower final debt
amount, the refinancing results in a high projected starting
leverage in 2019 of 7.3x on a funds from operations (FFO) adjusted
basis, versus 7.0x in 2018. This leverage will initially be outside
its sensitivity guidance for a negative rating action. However,
based on its projection of sustainably improved earnings Fitch
expects some deleveraging to 6.2x by 2022, which would firmly
anchor Rodenstock's financing risk profile at 'B-'.

Sustainable Business Model: Rodenstock benefits from a niche but
focused business model, with well-defined positions across
different distribution channels and compelling product competency,
especially in the technologically more advanced progressive lenses
sector. This allows the company to achieve profitability in line
with larger sector peers'.

Furthermore, the business model is underpinned by supportive
underlying trends such as an ageing population and the growth of
the number of people using glasses, with a higher presence of
progressive lenses rather than single and standardised vision
solutions. This offsets its high geographical concentration in
Germany and smaller scale than larger industry peers'. Under the
ownership of Compass Partners since 2016, Rodenstock has reinforced
and streamlined its operational focus on ophthalmic lenses.

Moderating Execution Risks: With the completion of the
comprehensive business refocusing and repositioning strategy
initiated by the new owner in 2016, execution risks are easing and
the business model has been strengthened. Consequently, Fitch views
Rodenstock better positioned to continue participating and
capitalising on favourable long-term global market trends. The
lenses division has recently seen above-market growth while other
segments have achieved sustainable profitability by the other
segments. However, the performance of the smaller eyewear unit
remains volatile.

Challenging, Competitive Environment: Its projections remain
cautious, reflecting a challenging competitive environment. In
particular the market is highly concentrated with dominance of much
larger peers, some of which with integrated retail platforms. At
the same time the growing power of optical chains is accelerating
market segmentation into value and premium optical products with
different dynamics and outreach strategies. This requires a
continuous reassessment and adaptation of Rodenstock's strategy to
evolving market conditions.

Improved Operating Profitability: Despite its lower scale, Fitch
regard Rodenstock's EBITDA margin of 20% as adequate for its
sector, having improved as a result of the business restructuring,
from 18%-19% previously. Fitch views this operating profitability
as sustainable in the medium term, albeit with limited scope for
further improvements due to persistent market risks, and given that
Rodenstock already generates operating margins in line with much
larger peers'. Furthermore, Fitch notes the dilutive effect of the
eyewear division, whose performance remains volatile in both
revenue and profitability terms, despite the group's turnaround
efforts since 2017.

Low Free Cash Flow Generation: Fitch forecasts Rodenstock's free
cash flow (FCF) will remain fragile and volatile despite
sustainable operational improvements, constrained by expected
higher cash tax, ongoing recurring and non-recurring charges
reflecting operating and market risks.

In 2019, Fitch expects FCF to be a negative EUR10 million (-2.3%
FCF margin) due to expected larger trade working capital outflows
to support business growth, and EUR5 million higher cash taxes
passed over from 2018. According to its projections, this will
reverse by 2022 with FCF improving gradually to EUR11 million and
2.3% FCF margin. However, this remains fairly modest, and a clear
attribute of a 'B-' credit risk, highlighting a limited organic
deleveraging capacity. Its FCF-to-debt ratio is weak at 1% to 2%,
due to the high capital intensity of Rodenstock as a manufacturing
company combined with a leveraged balance sheet.

Good Recovery Prospects for Senior Secured Debt: Under the recently
refinanced debt structure Fitch projects investors in the new TLB
and RCF will receive above-average recoveries as expressed in an
instrument rating of 'B'/'RR3'/70%. Fitch's recovery analysis uses
the going-concern approach for Rodenstock. This reflects the
group's business brand value, product know-how, proprietary
technology and established market position with long-term customer
relationships, all of which support higher values in a distress
scenario as opposed to a balance-sheet liquidation.

DERIVATION SUMMARY

Rodenstock is a mid-cap business with geographical concentration on
Germany, competing with much larger peers such as Essilor-Luxottica
(France; EUR16.1 billion revenue), Safilo (Italy; EUR1 billion
revenue), Carl Zeiss (Germany; around EUR5 billion revenue) and
Hoya (Japan; EUR4.1 billion revenue). However, technologically
Rodenstock is on a par with other market constituents in product
quality across the entire spectrum of affordable to premium optical
products, with a well-entrenched market position in the
higher-growth more profitable progressive lens business. This
technological competence is reflected in Rodenstock's operating
profitability being broadly in line with sector peers'.

As a medical device manufacturer Rodenstock fulfills a healthcare
requirement while seeking to meet consumer demand for glasses as a
fashion accessory. The operations benefit from positive long-term
demand fundamentals and the trend toward more technologically
advanced progressive lenses. At the same time, optical products in
Rodenstock's core market Germany still require a large
out-of-pocket share of expenses to be borne by the consumer,
particularly for the more expensive multi-focal ophthalmic lenses,
which may lead consumers to delay purchasing decisions or trade
down in periods of weaker macro-economic conditions.

This clearly differentiates the hybrid nature of Rodenstock as a
medical device and consumer credit from 3AB Optique Developpement
S.A.S. (Afflelou, B/Stable), a predominantly healthcare credit
benefiting from a supportive French reimbursement system. This
leads to more predictable operating performance, which in turn
allows higher funds from operations (FFO) gross leverage to remain
at or above around 6.0x through to 2022 compared with Rodenstock's
leverage sensitivity of below 6.0x to achieve the same 'B' IDR. In
addition, as a franchisor Afflelou benefits from lower capital
intensity and robust mid- to high-single digit FCF margins.

KEY ASSUMPTIONS

Fitch's Key Assumptions within its Rating Case for the Issuer
include:

  - Sales growing on average at 2.7% with lenses at 3.5%

  - EBITDA margins stable at around 20%
  
  - Sustainable capex at 6.3% - 7% of sales

  - Working capital cash outflows supporting growth

  - Annual cash pension contribution of EUR12.8 million

Recovery Assumptions:

In its recovery analysis Fitch follows a going concern approach
instead of balance-sheet liquidation. Its calculations reflect
Rodenstock's brand value, proprietary technology and established,
albeit niche, market position, in the European optical products
market. The going concern enterprise value (EV) of EUR321 million
is based on a post-distress EBITDA of EUR64 million resulting from
Fitch-adjusted 2018 EBITDA of EUR86 million, discounted by 25%.
Fitch regards this level of post-distress EBITDA to be appropriate
as it would be sufficient to cover a cash debt service cost of
EUR23 million, a cash pension cost of EUR12.8 million, estimatec
cash taxes under stressed scenario of around EUR5 million and a
sustainable level of capex of EUR20 million-EUR25 million to
maintain the viability of Rodenstock's business model.

Fitch has applied a distressed EV/EBITDA multiple of 5.0x, which is
in line with Fitch's estimated distressed valuation multiples for
comparable healthcare and consumer credits with moderate growth and
cash generation.

After deduction of 10% for administrative charges from the
post-distress EV of EUR321 million, its waterfall analysis
generates a ranked recovery for senior secured debt creditors,
including the new TLB and new RCF lenders, in the 'RR3' band,
leading to a 'B' instrument rating. The waterfall analysis output
percentage on current metrics and assumptions was 70% (previously
65%).

RATING SENSITIVITIES

Developments That May, Individually or Collectively, Lead to
Positive Rating Action

  - Sales growing sustainably by 2% or more in the coming years
(2018: 2.5%)

  - EBITDA margins at around 20% (2018: 20.1%)

  - Sustainably positive FCF in low to mid-single digits

  - FFO adjusted gross leverage below 6.0x (2018: 7.0x)

  - FFO fixed charge cover above 2.3x

Developments That May, Individually or Collectively, Lead to
Negative Rating Action

  - Tighter liquidity buffer reflected in a mostly negative FCF
profile and/or financial covenant breaches

  - Deteriorating competitive position leading to sustained erosion
in revenue, EBITDA and/or margins below EUR80 million and/or 19%
respectively

  - FFO adjusted gross leverage sustainably above 7.0x

  - FFO fixed charge cover below 2.0x

LIQUIDITY AND DEBT STRUCTURE

Modest but Improving Liquidity: Despite modest projected FCF
generation but growing steadily towards EUR11 million by 2022
(based on pre-IFRS 16 EBITDA forecasts), Fitch views Rodenstock's
liquidity position after refinancing as satisfactory. This is
primarily based on the long-term maturities of the new senior
secured facilities with no contractual repayments for the next 6.5
years for the RCF and seven years for the TLB.

In the absence of a clean-down provision and with a bullet
repayment profile, Rodenstock would be materially less constrained
by the requirements of the financing documentation, which would
allow the group to focus its efforts on operations. Fitch also
regards the committed RCF of EUR20 million as sufficient to cover
possible intra-year group funding requirements, creating an
additional external liquidity buffer on top of internally generated
liquidity. Fitch has assumed EUR10 million of RCF to be permanently
drawn to maintain adequate available cash reserves at year-end.

Its projections show steadily increasing year-end cash balances to
EUR32 million by December 2022 from EUR10 million in 2019. These
projected levels exclude restricted cash of EUR17 million,
comprising EUR14 million estimated as minimum cash required for
operations (mainly to fund intra-year trade working capital
requirements)and EUR3 million of cash designated for leases,
guarantees, as well as litigations.



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G R E E C E
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OPAP SA: S&P Places 'BB-' ICR on CreditWatch Neg.
-------------------------------------------------
S&P Global Ratings placed its 'BB-' issuer credit rating on
Greece-Based OPAP on CreditWatch with negative implications.

The CreditWatch placement mirrors the rating action on OPAP's
parent, Sazka, following Sazka's tender offer for OPAP. The
transaction is an all cash offer of EUR9.12 per share, representing
EUR2.06 billion for a 67% share of OPAP.

S&P said, "We understand that the Hellenic Capital Markets
Commission (HCMC) now has a couple of weeks to review the offer. If
the HCMC approves the offer, Sazka will proceed with the public
tender offer to the existing shareholders. The raised debt amount
will depend on the final stake acquired by Sazka, and therefore the
rating is subject to the transaction outcome. However, we
anticipate that Sazka's credit metrics will weaken--its adjusted
debt-to-EBITDA ratio is currently 3.0x-3.5x--and that there is a
possibility that we could lower our rating on Sazka on completion
of the transaction. We expect to obtain further information
regarding the potential acquisition within the next one to two
months."

CreditWatch

S&P said, "We expect to resolve the CreditWatch within the next
three months, upon completion of the potential acquisition and
after assessing Sazka's financial risk profile pro forma the
transaction, with emphasis on the ownership stake acquired and the
subsequent amount of debt raised.

"We would consider affirming the 'BB-' rating on OPAP and removing
it from CreditWatch negative if the pro forma credit metrics
support the current rating on Sazka or if the takeover does not
take place."



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I R E L A N D
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AVARA SHANNON: High Court Enters Wind Up Order
----------------------------------------------
Aodhan O'Faolain at The Irish Times reports that the High Court has
made orders winding up a Co Clare-based pharmaceutical company
employing more than 110 people.

Avara Shannon Pharmaceutical Services Ltd is hopelessly insolvent,
loss-making to the tune of EUR9.5 million a year and unable to pay
its workers, the court was told, the Irish Times relates.

The company is part of the Avara Pharma Group, which manufactures
chemicals, active ingredients in medicines, for the pharmaceutical
industry.

At the High Court on July 11, Ms. Justice Leonie Reynolds said she
was satisfied to appointed KPMG's Shane McCarthy and London-based
insolvency practitioner Edwin Kirker as joint provisional
liquidators to the company, which operates a 2,000 sq. m. facility
in Shannon Industrial Estate in Co Clare, according to the report.

The application to have the firm wound up was brought by the
company itself, the report notes.

According to the Irish Times, Rossa Fanning SC, with Ross Gorman,
for Avara, said the situation was "bleak", but there remained some
hope a buyer could be found.

Since the business was acquired for EUR1 in 2016 from UCB
Manufacturing Ltd, Avara had hoped it would be able to generate new
business but that had not materialised, counsel said, the report
relays.

At the time of the sale, the company and UCB entered into a supply
agreement where Avara would make Ritogotine, used to treat
Parkinson's disease, for UCB at a reduced price, the report says.

The Irish Times adds that UCB also contributed to Avara's overheads
for two years in the hope the company would be profitable after the
two-year period expired.

Avara broke even between 2016 and 2018, but since then had been
loss-making, counsel, as cited by The Irish Times, said.

The Avara group had been supporting the company financially to the
tune of EUR16 million, but could no longer afford to do this, he
said. It sought a buyer but that had not been possible, the report
states.

The Irish Times adds the company had considered liquidation in
April but decided against that option in order to convert EUR3
million worth of active ingredients into finished goods that
otherwise would have been worthless.

According to the report, counsel said that decision meant the
company did trade profitably between April and the end of June but
the overall picture was poor, and the firm was hopelessly
insolvent.

The Irish Times relates that the company did not have the funds to
pay money sought by the employees whose representatives had
informed Avara they expected their rights under the Transfer of
Undertakings (Protection of Employment) Regulations 2006--being 6
1/2 weeks' pay totalling some EUR16 million--to be honoured.

The issue had been before the Workplace Relations Commission and
the Labour Court. The company says it cannot pay the level of
redundancy being sought which, Avara says, was agreed by the
previous owner UCB, counsel outlined, according to the report.

As a result of not being able to reach an agreement, all 115
employees had earlier this month voted for strike action, he said.

The judge has returned the matter to later this month, the report
notes.

BARINGS EURO 2019-1: Moody's Rates EUR8.8MM Cl. F Notes (P)B3(sf)
-----------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following provisional ratings to notes to be issued by Barings Euro
CLO 2019-1 Designated Activity Company:

EUR242,000,000 Class A Senior Secured Floating Rate Notes due 2032,
Assigned (P)Aaa (sf)

EUR22,200,000 Class B-1 Senior Secured Floating Rate Notes due
2032, Assigned (P)Aa2 (sf)

EUR19,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2032,
Assigned (P)Aa2 (sf)

EUR14,400,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes due 2032, Assigned (P)A2 (sf)

EUR12,000,000 Class C-2 Senior Secured Deferrable Fixed Rate Notes
due 2032, Assigned (P)A2 (sf)

EUR26,400,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)Baa3 (sf)

EUR23,600,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)Ba3 (sf)

EUR8,800,000 Class F Senior Secured Deferrable Floating Rate Notes
due 2032, Assigned (P)B3 (sf)

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavour to
assign definitive ratings. A definitive rating (if any) may differ
from a provisional rating.

RATINGS RATIONALE

The rationale for the rating is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

The Issuer is a managed cash flow CLO. At least 90% of the
portfolio must consist of senior secured obligations and up to 10%
of the portfolio may consist of senior unsecured obligations,
second-lien loans, mezzanine obligations and high yield bonds. The
portfolio is expected to be approximately 90% ramped as of the
closing date and to comprise predominantly corporate loans to
obligors domiciled in Western Europe. The remainder of the
portfolio will be acquired during the 6 month ramp-up period in
compliance with the portfolio guidelines.

Barings (U.K.) Limited will manage the CLO. It will direct the
selection, acquisition and disposition of collateral on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's four and a half
year reinvestment period. Thereafter, subject to certain
restrictions, purchases are permitted using principal proceeds from
unscheduled principal payments and proceeds from sales of credit
risk obligations.

In addition to the eight classes of notes rated by Moody's, the
Issuer will issue EUR 38.8m of Subordinated Notes which will not be
rated.

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

Methodology underlying the rating action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
March 2019.

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

The rated notes' performance is subject to uncertainty. The notes'
performance is sensitive to the performance of the underlying
portfolio, which in turn depends on economic and credit conditions
that may change. The collateral manager's investment decisions and
management of the transaction will also affect the notes'
performance.

Moody's modeled the transaction using CDOEdge, a cash flow model
based on the Binomial Expansion Technique, as described in Section
2.3 of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

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

Par Amount: EUR 400,000,000

Diversity Score: 48

Weighted Average Rating Factor (WARF): 2910

Weighted Average Spread (WAS): 3.65%

Weighted Average Coupon (WAC): 5.50%

Weighted Average Recovery Rate (WARR): 43.0%

Weighted Average Life (WAL): 8.5 years

Moody's has addressed the potential exposure to obligors domiciled
in countries with local currency ceiling (LCC) of A1 or below. As
per the portfolio constraints and eligibility criteria, exposures
to countries with LCC of A1 to A3 cannot exceed 10% and obligors
cannot be domiciled in countries with LCC below A3.



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N E T H E R L A N D S
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INTERXION HOLDING: S&P Raises LT ICR to 'BB' on Equity Issuance
---------------------------------------------------------------
S&P Global Ratings raised to 'BB' from 'BB-' its long-term issuer
credit rating on Interxion Holding N.V. and its issue ratings on
its EUR300 million revolving credit facility (RCF) and EUR1.2
billion senior unsecured notes.

S&P said, "The upgrade follows Interxion's common equity issuance
of about EUR290 million, and reflects our expectation that the
company will use the proceeds for land bank development and the
expansion of data center capacity. We think the equity offering
will improve Interxion's financial flexibility, and keep its S&P
Global Ratings-adjusted debt to EBITDA largely stable at about 5x
in 2019. With the planned expansion, we also expect Interxion's
property ownership ratio will significantly increase in 2020, from
55% in the first quarter of 2019, bringing it closer to that of
other data center providers like Global Switch.

"We think Interxion can sustain somewhat higher leverage at the
'BB' rating level, given its increased property ownership,
relatively predictable growth in rental revenue, and the leverage
ratio of peers at the same rating level. We think the higher
ownership will give Interxion better control over its space
planning and allow it to better meet customer needs." It also
reduces the risk of non-renewal of its lease contract or price
hikes.

The higher rating is also supported by Interxion's strong market
position in Europe, large and diversified customer base, and
improving customer contract structure. Interxion is the
second-largest network and cloud-neutral data center operator in
Europe after Equinix. It operates 52 data centers in 11 countries
and services more than 700 connectivity providers, 500 platform
providers, and 20 internet exchanges. S&P said, "We think the large
and diversified customer base offers Interxion good opportunities
to provide interconnection services, allowing customers to have
fast and secure private access to one another. It also creates a
relatively high barrier for new entrants. We think Interxion's
customer contract composition has significantly improved, supported
by the increasing share of contracts with large platform and
content providers. Its current average contract duration is about
three to five years."

S&P said, "The rating also incorporates our expectation that
Interxion will continue to post significant negative free operating
cash flow (FOCF) due to its aggressive expansion plan. We expect
negative FOCF of more than EUR400 million in 2019 and 2020, mainly
on the back of expansion capex of approximately EUR600 million,
which we think would be funded by a mix of equity, cash, and new
debt. Despite the significant cash burn, we think Interxion has a
good track record of maintaining strong operational performance and
prudent liquidity. We note that Interxion starts new projects only
if the committed cash resources are available, and depending on
their expectation of existing customers' needs and a presale target
of at least 25% of the space. Interxion's utilization rate has
remained largely stable at about 80% in the past three years and an
adjusted EBITDA margin of 50%, in line with rated peers like
Equinix. In addition, the recent equity issuance provides a
positive signal, in our view, that Interxion will supplement equity
with debt issuance to fund its future investments.

"The stable outlook reflects our expectation that Interxion will
continue to benefit from strong demand for its data centers,
resulting in revenue growth of 13%-15%. We also expect that using
debt and equity funding for its expansion will help Interxion
maintain adjusted debt to EBITDA not materially above 5x from 2020,
FFO to debt of 12%-15%, and adequate liquidity. The outlook also
reflects our expectation of adjusted EBITDA margins of about 50%."

Downside scenario

S&P could lower its rating if Interxion becomes more aggressive on
debt-funded expansions, coupled with a significantly lower
utilization rate and margins, leading to adjusted debt to EBITDA
above 6x and FFO to debt of less than 12% on a prolonged basis.

Upside scenario

S&P said, "We see short-term prospects for an upgrade as remote
given our expectation of continued cash burn on the back of
material growth-related capex. We could raise the rating if the
group continues to increase its revenues and margins, improving
adjusted debt to EBITDA sustainably to less than 4.5x and adjusted
FFO to debt to above 20%, while achieving positive FOCF." This
would most likely result from significantly higher capacity
utilization and free cash flow through a slowdown in expansions.




===========
N O R W A Y
===========

SECTOR ALARM: S&P Assigns 'B' Issuer Credit Rating, Outlook Stable
------------------------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to Norway-based Sector Alarm Holding AS (Sector Alarm) and its 'B'
long-term issue-level and '3' recovery ratings to the group's
EUR590 million (NOK6 billion) term loan B and EUR100 million
revolving credit facility (RCF).

The 'B' rating reflects Sector Alarm's high debt leverage, with S&P
Global Ratings-adjusted debt to EBITDA of around 5.6x expected at
the end of 2019, its modest revenue, high geographic concentration,
and exposure to technology risks. The rating is supported by the
company's integrated business model in the residential alarm value
chain, with low customer attrition and predominantly recurring
revenue (95% of total revenue) resulting in predictable cash flows,
and its proven ability to penetrate and scale existing and new
European markets, which, given the low level of penetration in
Europe, could drive strong growth in the future.

S&P said, "This rating action is in line with our preliminary
ratings, which we assigned on May 24, 2019. There were no material
changes to our base case or the financial documentation compared to
our original review. For a more detail rating rationale, see
"Residential Security Solutions Provider Sector Alarm Holding AS
Assigned Preliminary 'B' Rating; Stable Outlook," published on
RatingsDirect.

"The stable outlook reflects our expectation that the company will
continue to invest in subscriber growth resulting in strong annual
revenue growth of around 7%-10% through 2020, with an adjusted
EBITDA margin in the low-40% range. We expect these investments
will result in minimal, but positive, free cash flow and adjusted
debt to EBITDA remaining above 5x through 2020.

"We could raise the rating if continued growth in EBITDA reduces
adjusted debt to EBITDA to less than 5x, supported by a more
conservative financial policy. An upgrade would require revenue and
EBITDA to at least remain stable.

"We could lower the rating if technological disruption, operational
missteps, or other factors result in declining EBITDA and negative
free cash flow, or if the company adopts a more aggressive
financial policy such that adjusted debt to EBITDA increases above
7x.

"We are assigning our 'B' issue rating to Sector Alarm's EUR590
million senior secured term loan and EUR100 million RCF.

"The recovery rating on the senior secured debt is '3', indicating
our expectation of meaningful recovery (rounded estimate 60%) of
principal in the event of payment default. The recovery prospects
are supported by the limited amount of priority claims ranking
ahead of the secured debt in the waterfall and the fairly
substantial cushion of unsecured debt."

The documentation includes springing leverage covenants under the
RCF, triggered if more than 40% of commitments are drawn.

S&P said, "In our hypothetical default scenario, we contemplate a
default in 2022 as a result of increased customer attrition due to
technological disruption leading to higher investments, increased
financial leverage, and a large interest burden.

"We value Sector Alarm as a going concern, given its strong
position in the European security services market for homes and
small businesses, strong brand name, and resilient growth from its
portfolio of good quality customers."

Simulated default assumptions

-- Year of default: 2022
-- EBITDA at emergence: NOK838 million
-- Implied enterprise value multiple: 5.5x
-- Jurisdiction: Norway

Simplified waterfall

-- Gross enterprise value at default: NOK4.5 billion
-- Administrative costs: 5%
-- Net value available to creditors: NOK4.3 billion
-- Senior secured debt claims: NOK7 billion*
-- Recovery expectations on senior secured debt claims: 60%**

* All debt amounts include six months of prepetition interest. RCF
assumed 85% drawn on the path to default.
** Rounded down to the nearest 5%.



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

CB ASSOTSIATSIYA: Put on Provisional Administration
---------------------------------------------------
The Bank of Russia, by virtue of its Order No. OD-1758, dated July
29, 2019, revoked the banking license of Nizhny Novgorod-based
credit institution Joint-stock Company Commercial Bank
Assotsiatsiya, or JSC CB Assotsiatsiya (Registration No. 732,
hereinafter, Bank Assotsiatsiya).  The credit institution ranked
170th by assets in the Russian banking system.

The Bank of Russia took this decision in accordance with Clause 6,
Part 1 and Clauses 1 and 2, Part 2, Article 20 of the Federal Law
"On Banks and Banking Activities", based on the facts that Bank
Assotsiatsiya:

   -- admitted the absence of funds in accounts with a foreign
bank, which were reflected in financial reports. Creation of
additional required loss provisions for actually non-existent
assets led to a complete loss of capital by the credit
institution;

   -- violated federal banking laws and Bank of Russia regulations,
making the regulator repeatedly apply supervisory measures over the
past 12 months, including the imposition of restrictions on
household deposit taking.

As part of ongoing supervision, the Bank of Russia established the
fact of absence of funds in the amount of over RUR3.8 billion in
accounts of Bank Assotsiatsiya with a foreign bank, which exceeds
its equity capital more than twofold.  The management of the credit
institution admitted the absence of the above-mentioned funds.  The
regulator issued an order to Bank Assotsiatsiya to create
additional loss provisions for actually missing claims on a foreign
bank in the amount of 100%.  According to the latest financial
statements submitted by the bank, its capital was completely lost.

The Bank of Russia will submit information about the bank’s
transactions suggesting a criminal offence to law enforcement
agencies.

The Bank of Russia appointed a provisional administration to Bank
Assotsiatsiya for the period until the appointment of a receiver4
or a liquidator.  In accordance with federal laws, the powers of
the credit institution’s executive bodies were suspended.

Information for depositors: Bank Assotsiatsiya is a participant in
the deposit insurance system; therefore, depositors6 will be
compensated for their deposits in the amount of 100% of the balance
of funds but no more than a total of RUR1.4 million per depositor
(including interest accrued).

Deposits are repaid by the State Corporation Deposit Insurance
Agency (hereinafter, the Agency). Detailed information regarding
the repayment procedure can be obtained 24/7 at the Agency’s
hotline (8 800 200-08-05) and on its website
(https://www.asv.org.ru/) in the Deposit Insurance / Insurance
Events section.


FG BCS: S&P Raises LT ICR to 'B', Outlook Positive
--------------------------------------------------
S&P Global Ratings raised its long-term issuer credit rating on FG
BCS Ltd. to 'B' from 'B-'. The outlook is positive. At the same
time, S&P affirmed its 'B' short-term issuer credit rating on the
group.

This rating action follows a review of FG BCS under S&P's revised
criteria.

S&P said, "Our positive outlook on FG BCS reflects the possibility
of an upgrade in the next 12-18 months if the group demonstrates
effective operations and management of all the risks associated
with the increasing complexity of its operations, while maintaining
a sufficient capital buffer.

"We are likely to raise the ratings if we see the BCS group
maintaining strong capitalization while adequately managing risks
associated with its growth, changes in corporate structure, and
hedging strategy. We could also consider an upgrade if the group
achieves stronger geographic diversification outside Russia, which
may come from its expanding prime brokerage activities.

"We may revise the outlook to stable if, contrary to our
expectations, the group's risk-adjusted capital (RAC) ratio dropped
below 10% and earnings declined materially. An outlook revision to
stable could also stem from deterioration of the group's risk
profile.

"The upgrade of FG BCS, a Cyprus-incorporated nonoperating holding
company, reflects our view that its creditors remain structurally
subordinated to those of its operating companies, but that they
face less risk than is typical among broker groups globally. We
have therefore narrowed to one from two the notches between our
'b+' assessment of the group credit profile (GCP) and our long-term
issuer credit rating on FG BCS.

"Our reassessment of FG BGS structural subordination centers on our
view that there is only moderate potential for regulatory
restrictions to payment of dividends by group operating companies
to FG BCS. Specifically, we believe that securities companies in
Russia, which are regulated by the Central Bank of Russia, have
looser regulation than securities companies in Europe and in the
U.S." The size of prudentially regulated U.K.-based subsidiary BCS
Prime Brokerage Ltd. and Russia-based subsidiary BCS Bank is
relatively small in the scope of the group. Moreover, FG BCS has no
outstanding debt and therefore minimal liquidity needs.

"This view of relatively lighter regulation for Russian securities
firms is also captured in our 'b' anchor (the starting point for
our rating assessment); it is two notches below the anchor for
Russian banks. The lower anchor for Russian securities firms
reflects our view that these entities face higher industry risk
than domestic banks because of their weaker institutional
framework, higher competitive risk, challenged revenue dynamics,
and increased funding risk, because of the lack of central bank
access and less liquid, more volatile domestic capital markets.

"Our assessment of the BCS group's intrinsic credit strength is
unchanged. We view the group as one of the largest and most
diversified brokers in the Russian market, with a 25% share of
equity market turnover and 12% of retail clients across Russia. We
also consider the group's notable international presence and its
gradual emergence as a key execution platform for international
players in Russia-related markets.

"We regard the group's capitalization as strong and expect its RAC
ratio to stay at around 14%-15%. Earnings have been strong since
2015, when the group's efforts to build infrastructure started to
pay off. Risk-management procedures are sound, in our view, and
commensurate with the complexity of the group's operations and
activities, which take place across multiple jurisdictions and
regulatory regimes. At the same time, the group has exhibited some
appetite toward diversity, eagerly developing new businesses, and
complex products. We also note that the group has shifted to more
stable sources of funding and maintains an adequate liquidity
cushion."

KRASNODAR CITY: Moody's Alters Outlook on B1 Issuer Rating to Pos.
------------------------------------------------------------------
Moody's Investors Service changed to positive from stable the
outlooks on the issuer ratings of Samara, Oblast of (Ba2), Nizhniy
Novgorod, Oblast (Ba3), Krasnodar, Krai of (Ba3) and Krasnodar,
City of (B1). At the same time, Moody's has affirmed the issuer
ratings of these four sub-sovereigns.

The changes in outlooks reflect Moody's view regarding these
regions' healthy revenue growth and the conservative budgetary and
debt management policies resulting in reducing debt levels and
refinancing risks. The year-to-date strong progress in tax
administration and excellent performance in corporate and personal
income taxes made Moody's revise previous expectations regarding
these regions' pace of deleveraging. In addition, the Russian
federal government's recent measures to ensure regions are
effectively targeting economic growth and social improvements while
tightly controlling budget deficits and new borrowings provide
better predictability of the regions' future financial policy.

RATINGS RATIONALE

  -- SAMARA, OBLAST OF

The affirmation of the issuer's Ba2 rating and the change of the
outlook to positive from stable reflects stronger than previously
expected revenue growth that together with a tight control over
expenditures enables faster reduction in leverage. A longer track
record of the prevailing trends will allow not only to decrease
leverage and secure lower refinancing risks but also improves
policy predictability, helping to decrease the region's
historically elevated financial metrics' volatility.

A recent track record of conservative budgetary and debt management
has enabled the region to reduce leverage. As of year-end 2018, the
region's ratio of net direct and indirect debt (NDID) to operating
revenues totaled 34%, having decreased from 50% in 2016, and
Moody's expects this ratio to further drop below 30% in 2020. Along
with the ongoing rapid deleveraging, the region's authorities have
also accumulated a larger liquidity buffer that, as of year-end
2018, exceeded 6% of the region's operating revenues. The region
also improved its debt structure, being more reliant on the
long-term debt instruments. A longer track record of such
conservative stance could warrant an upgrade of the issuer ratings
in the next 12 to 18 months.

  -- NIZHNIY NOVGOROD, OBLAST

The affirmation of the issuer's Ba3 rating and the change of the
outlook to positive from stable reflects stronger than previously
expected revenue growth and Moody's expectations of faster debt
metrics improvements thanks to the ongoing conservative budgetary
stance and better tax administration. The ongoing revenue growth
and authorities' tight control over operating expenditures are
expected to further reduce leverage and refinancing risk. At
year-end 2018, the region's ratio of NDID to operating revenues was
48% (against 64% in 2015), and Moody's expects this ratio to drop
below 45% in 2020. Moreover, the region's authorities accumulated a
larger liquidity buffer that exceeded 8% of the region's operating
revenues (at year-end 2018) and are currently improving the
region's debt structure to be more reliant on longer-term debt
instruments. Further sustained improvements in the region's
financial metrics could warrant an upgrade of the issuer ratings in
the next 12 to 18 months.

  -- KRASNODAR, KRAI OF

The affirmation of the issuer's Ba3 rating and the change of the
outlook to positive from stable reflects Moody's expectations of a
further debt metrics improvements thanks to the ongoing
conservative budgetary stance. Significant revenue growth combined
with conservative debt management should further reduce leverage
and refinancing risk in the next two to three years. Moody's
expects the NDID to revenue ratio to reach 45% in 2020 against 57%
at year-end 2018. The regional authorities also built up a
liquidity buffer representing 11% of the region's operating
revenues at year-end 2018. They are also less reliant on short-term
debt. Further sustained improvements in the region's financial
metrics could warrant an upgrade of the issuer ratings in the next
12 to 18 months.

  -- KRASNODAR, CITY OF

The affirmation of the issuer's B1 rating and the change of the
outlook to positive from stable reflects the city's fiscal
consolidation which resulted in positive operating balance from
2017. Moreover, the ongoing support received from the regional
authorities (Krasnodar, Krai of) in the form of budget loans will
help to minimize refinancing risks and decrease the city's debt
service costs.

  -- WHAT COULD CHANGE THE RATINGS UP/DOWN

A longer track record of sustained improvements in leverage and
refinancing risks could trigger Moody's to upgrade the issuer
ratings of these four sub-sovereigns. The upgrade in the sovereign
rating could also exert upward credit pressure on the ratings.

Given the recent change of the outlook to positive, negative credit
pressures are unlikely to develop for the issuers covered in the
rating action. At the same time, any unexpected deterioration in
the credit metrics of these sub-sovereigns, i.e. unexpected revenue
declines or expenditure pressure resulting into opposite debt
trends, could exert downward pressure on their ratings or
outlooks.

  -- RATINGS AFFECTED

Affirmations:

Issuer: Krasnodar, Krai of

LT Issuer Rating, affirmed Ba3

Issuer: Nizhniy Novgorod, Oblast

LT Issuer Rating, affirmed Ba3

Issuer: Samara, Oblast of

LT Issuer Rating, affirmed Ba2

Senior Unsecured Regular Bond/Debenture, affirmed Ba2

Issuer: Krasnodar, City of

LT Issuer Rating, Affirmed B1

Outlook Actions:

Issuer: Samara, Oblast of

Outlook, Changed to Positive from Stable

Issuer: Krasnodar, Krai of

Outlook, Changed To Positive From Stable

Issuer: Nizhniy Novgorod, Oblast

Outlook, Changed to Positive from Stable

Issuer: Krasnodar, City of

Outlook, Changed to Positive from Stable

The reason for the deviation reflects Moody's recognition of the
ongoing rapid regions' revenue growth as reflected in their
recently financial statements for the first five months of 2019.

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

Sovereign Issuer: Russia, Government of

GDP per capita (PPP basis, US$): 29,267 (2018 Actual) (also known
as Per Capita Income)

Real GDP growth (% change): 2.3% (2018 Actual) (also known as GDP
Growth)

Inflation Rate (CPI, % change Dec/Dec): 4.3% (2018 Actual)

Gen. Gov. Financial Balance/GDP: 2.9% (2018 Actual) (also known as
Fiscal Balance)

Current Account Balance/GDP: 6.9% (2018 Actual) (also known as
External Balance)

External debt/GDP: [not available]

Level of economic development: Moderate level of economic
resilience

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

On July 23, 2019, a rating committee was called to discuss the
rating of the Krasnodar, City of; Krasnodar, Krai of; Nizhniy
Novgorod, Oblast; Samara, Oblast of. The main points raised during
the discussion were: The issuer's governance and/or management,
have materially increased. The issuer's fiscal or financial
strength, including its debt profile, has materially increased. An
analysis of this issuer, relative to its peers, indicates that a
repositioning of its rating would be appropriate.

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

VOZROZHDENIE BANK: S&P Withdraws 'B+/B' Issuer Credit Ratings
-------------------------------------------------------------
S&P Global Ratings withdrew its 'B+/B' long- and short-term global
scale issuer credit ratings on Russia-based Vozrozhdenie Bank at
the bank's request. At the time of withdrawal, the outlook was
positive.




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

DISTRIBUIDORA INTERNACIONAL: Moody's Confirms Caa1 CFR, Outlook Neg
-------------------------------------------------------------------
Moody's Investors Service confirmed the Caa1 long-term corporate
family rating, the Caa1-PD probability of default rating, and the
Caa2 senior unsecured ratings of the bonds and the (P)Caa2 senior
unsecured MTN program rating of Spain-based food retailer
Distribuidora Internacional de Alimentacion. Moody's has changed
the outlook to negative from rating under review.

The action concludes the review process that was initiated on 20
December 2018.

"The confirmation of DIA's rating reflects its improved liquidity
following the refinancing of its bank debt and the EUR490 million
equity injection from the investment fund L1," says Vincent
Gusdorf, a Moody's Vice President -- Senior Credit Officer and lead
analyst for DIA. "Although liquidity concerns have eased, DIA has
fallen behind competitors and faces a challenge to substantially
improve its business model to close the gap and stop the current
level of cash burn."

RATINGS RATIONALE

Following the repayment of the EUR306 million bond due on July 22,
2019 and the refinancing of its bank debt, DIA will face no
meaningful debt maturities until the maturity of its EUR300 million
bond due in April 2021.

Under the terms of the refinancing agreement completed on June 25,
2019, banks have agreed to extend the maturities of their
syndicated credit facilities until March 31, 2023. Covenants will
be suspended until December 31, 2020 and DIA will have access to
EUR280 million of new super senior secured facilities.

To bolster its capital structure, DIA also intends to implement a
EUR600 million capital increase by the end of 2019. Although this
transaction will require the vote of DIA's shareholders, its
probability of success is high because investment fund L1, which
owns 70% of DIA's shares, has indicated that it will vote in favour
of the resolution. L1 has already advanced EUR490 million to DIA
via participatory loans.

A more stable capital structure will give management time to turn
operations around and restore suppliers' and customers' confidence.
Because of its financial issues, Moody's believes that DIA has
fallen well behind market leader Mercadona and German discounter
Lidl, which have steadily gained market share in recent years. DIA
plans to address its weaker market position by implementing a
wide-ranging strategic plan, which includes, among other things, a
review of its product offering, a strengthening of its private
label range and a new pricing policy.

Moody's views DIA's liquidity as adequate for the next 12 months,
but it could deteriorate quickly if the new management fails to
stop the cash burn. The company had EUR118 million of cash as of
March 31, 2019, and access to a EUR280 million super senior loan
maturing in 2022. The company also received EUR490 million from L1
in the form of participatory loans in June 2019, which were largely
used to repay the EUR306 million bond due in July 2019. Although
the company has minimal debt maturities until the EUR300 million
bond falls due in April 2021, Moody's expects the company's free
cash flow to remain negative until 2020, despite a seasonal cash
inflow related to working capital during the second half of 2019.

Moody's believes that L1 will exert significant influence on DIA's
governance. L1 has appointed DIA's chairman as well as two of the
five board directors, although the remaining three members are
considered independent by the company. Moody's assessment of DIA's
credit quality will hinge notably on its governance standards, the
transparency of its accounting policies and possible changes in
DIA's ownership structure.

STRUCTURAL CONSIDERATIONS

The CFR is located at the level of Distribuidora Internacional de
Alimentacion S.A., the top entity of the group. Moody's estimates
that DIA's gross reported debt stood at about EUR1,500 million
following the repayment of the EUR306 million bond in July 2019.
This debt encompasses EUR600 million unsecured bonds, which Moody's
rates at Caa2, one notch below the CFR given that they are
subordinated to other debt. This other debt includes EUR900 million
of credit facilities, which benefit from a security package,
including the international assets of the group that account for a
sizable portion of DIA's total assets. DIA also has access to
EUR280 million in super senior credit facilities which are
secured.

Moody's Loss Given Default analysis is based on an expected family
recovery rate of 50%, which reflects a capital structure comprising
secured bank debts and unsecured notes.

RATIONALE FOR THE NEGATIVE OUTLOOK

Moody's believes that the recent debt refinancing and the upcoming
EUR600 million capital increase should enable DIA to maintain
adequate liquidity over the next 12 months. However, the negative
outlook reflects Moody's expectation that negative free cash flow,
if unabated, could still put pressure on overall liquidity beyond
12 months. One of the company's main challenges is to restore
suppliers' and consumers' confidence, as well as substantially
improve its business model, in order to sustainably improve its
earnings and strengthen its cash flow generation.

WHAT COULD CHANGE THE RATING UP/DOWN

Although unlikely in the near-term in light of the negative
outlook, there could be positive pressure on DIA's ratings if it
improved its earnings significantly following a successful
implementation of its transformation plan, while ending the current
cash burn. A positive rating action would also require that
liquidity remained adequate and that DIA evidences sound corporate
governance and reporting standards. Quantitatively, Moody's could
upgrade DIA if its Moody's-adjusted EBIT/interest expenses rose
above 1.2x on a sustainable basis.

Moody's could downgrade DIA's rating if it failed to reverse its
structural earnings decline, possibly because of sustained market
share losses stemming from a failure to rebuild good relationships
with customers and suppliers. Weakening liquidity or sustainably
negative FCF could also cause a negative rating action.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Retail Industry
published in May 2018.

DISTRIBUIDORA INTERNACIONAL: S&P Affirms 'CCC' LT ICR, Outlook Neg
------------------------------------------------------------------
S&P Global Ratings affirmed its 'CCC' long-term issuer credit
rating on Distribuidora Internacional de Alimentacion S.A. (DIA).
At the same time, the increased amount of priority bank debt in
DIA's capital structure leads S&P to revise downward its recovery
rating on DIA's unsecured notes to '6' from '4' and lower the issue
rating to 'CC' from 'CCC'.

Despite some positive developments around DIA's capital structure
and liquidity in the past weeks, the company's still-elevated
leverage--with financial net debt estimated around EUR1.5 billion
at end-July 2019--underpins S&P's view that its current capital
structure remains unsustainable. In particular, S&P notes the
following uncertainties regarding the timing and execution of DIA's
planned measures:

-- The nature and scope of the new management's strategic plan,
which we understand is still on the drawing board;

-- The group's ability to effectively carry out the strategic plan
and turn around its operations;

-- The amount of restructuring costs needed to implement the
turnaround plan;

-- The planned EUR600 million capital increase and conversion of
main shareholder LetterOne's PPL into equity;

-- The announced disposal of the Max Descuento and Clarel
businesses; and

-- DIA's ability to refinance or repay the EUR600 million bonds
maturing in April 2021 and 2023.

DIA has successfully amended and extended the maturity of its
EUR902 million syndicated credit facilities to March 2023 from May
2019. In addition, the group used the cash proceeds of the EUR490
million PPL from its shareholder LetterOne to repay its EUR306
million bonds due July 22, 2019.

These transactions, together with the received commitments for
additional super senior facilities of EUR271 million (in the form
of a EUR71 million confirming line and EUR200 million delayed drawn
term loan) have materially improved the group's near-term liquidity
situation. S&P expects DIA to have sufficient financial means to
initiate the turnaround of its operations over the next 12 months.

Furthermore, with the injection of EUR490 million from the
LetterOne PPL, DIA resolved its negative equity situation that
would have forced the board of directors, under the Companies Act,
to request DIA's dissolution. S&P understands that the PPL will be
converted into equity upon completion of the group's announced
EUR600 million capital increase later this year.

Yet, DIA's operating performance in the first months of 2019 was
very weak. There was a 4.3% like-for-like sales decline in the
first quarter, and an 85.8% drop in adjusted EBITDA (as calculated
by the company) from the EUR84.8 million reported in the same
period last year. Trading was affected by a contraction of trade
insurance and supplier volumes granted to the group, which led to a
substantial increase in out-of-stock levels in stores. DIA also
faced the impact of its first initiatives to reposition its
business model, such as the de-franchising process.

S&P said, "We anticipate that DIA's business model will need to
undergo a prolonged and heavy transformation to regain
competitiveness and restore margins. Such a transformation will
likely carry some execution risks, especially with regard to the
pace and scope of the proposed implementation. DIA is likely to
incur sizable restructuring costs that will further weigh on the
group's profitability. This is in a context of extreme competitive
pressure, in particular in Spain from market leader Mercadona,
forcing the group to be very competitive on prices. We also factor
in the ongoing negative impact of currency movements in its Latin
American operations that more than offset the healthy underlying
trend of its operations in that region.

"We understand that DIA's new management is currently reviewing and
finalizing the group's market positioning, strategic and
operational focus, in light of the various challenges it faces."

The negative outlook reflects DIA's weak earnings and cash flow
generation profile, as well as the significant challenges it faces
to turn its operations around in the unfavorable market context in
Spain, Brazil, and Argentina. As such, despite S&P's assumption
that DIA will not face a near-term liquidity shortfall, it believes
its current capital structure is unsustainable in the short to
medium term.

Downside scenario

S&P will lower the ratings if DIA's operating performance
deteriorates further or its liquidity weakens, leading it to assess
that a default, distressed exchange, or restructuring have taken
place or are inevitable within six months.

Upside scenario

S&P could revise the outlook to stable or take a positive rating
action when it has more visibility on the group's strategic and
turnaround plan and financial policy framework, together with signs
of stabilization and improvement of DIA's earnings and cash flows.



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

ARTS LTD: Fitch Downgrades DPR Notes to BB+, Outlook Negative
-------------------------------------------------------------
Fitch Ratings has downgraded the following seven Turkish
diversified payment rights programmes' debt:

A.R.T.S. Ltd. (ARTS, originated by Akbank T.A.S. (Akbank; Long-Term
Local-Currency Issuer Default Rating (LC IDR) B+/Negative)

Bosphorus Financial Services Limited (Bosphorus, originated by QNB
Finansbank A.S. (QNB Finansbank; LC IDR BB-/Negative)

DFS Funding Corp (DFS, originated by Denizbank A.S. (Denizbank; LC
IDR BB-/Negative)

Garanti Diversified Payment Rights Finance Company (Garanti DPR,
originated by Turkiye Garanti Bankasi A.S. (Garanti; LC IDR
BB-/Negative)

TIB Diversified Payment Rights Finance Company (TIB DPR, originated
by Turkiye Is Bankasi A.S. (Isbank; LC IDR B+/Negative)

VB DPR Finance Company (VB DPR, originated by Turkiye Vakiflar
Bankasi T.A.O. (Vakifbank; LC IDR BB-/Negative)

Yapi Kredi Diversified Payment Rights Finance Company Ltd (Yapi
DPR, originated by Yapi ve Kredi Bankasi A.S. (Yapi Kredi; LC IDR
BB-/Negative).

The Outlook on the DPR ratings is Negative. This reflects the
Negative Outlooks on the originating banks' LC IDRs and on the
Turkish sovereign rating.

The DPR programmes are financial future flow securitisations backed
by the originating bank's generation of foreign currency flows
(typically denominated in US dollars, euros or sterling).
Collateral consists of existing and future rights of the bank to
receive foreign currency payments into their accounts with
correspondent banks abroad. DPRs can arise for a variety of reasons
including payments due on the export of goods and services, capital
flows, tourism and personal remittances.

KEY RATING DRIVERS

Fitch has maintained the Going Concern Assessment (GCA) scores
assigned to the originating banks. QNB Finansbank A.S. has a GC2
score and Denizbank A.S. has a GC3 score, while all the other banks
have a GC1 score.

Fitch continues to view the high systemic stress in Turkey to be
more significant than the differentiating factors between the
programmes over the short to medium term. The heightened doubts
over the authorities' tolerance for a period of sustained
below-trend growth and disinflation have further impaired the
visibility on the outcome of any potential default or bankruptcy
scenario for each bank involved.

Fitch has maintained the notching differential between the DPR
rating and the respective originator's LC IDR and continued to
equalise the programme ratings for ARTS, TIB DPR, Garanti DPR, Yapi
DPR and VB DPR, which are one notch higher than those of Bosphorus
and DFS.

Fitch has tested the sufficiency and sustainability of the debt
service coverages under various scenarios, including interest rate
and FX stresses, a reduction in payment orders based on the top 20
beneficiary concentrations and a reduction in remittances based on
the steepest quarterly decline in the last five years. Fitch
considers that the debt service coverage ratios (DSCRs) for all
seven programmes are currently sufficient to support their ratings.


ARTS (BB+/Negative)

Fitch has downgraded ARTS' DPR notes by one notch to 'BB+' from
'BBB-'. The 'BB+' DPR rating reflects an unchanged three-notch
uplift from Akbank's LC IDR of 'B+'. Fitch calculates the monthly
DSCR for the programme at 62x based on the monthly average offshore
flows processed through designated depositary banks (DDBs) of the
past 12 months and 44x based on the lowest monthly flows in the
past five years, after incorporating interest rate stresses.

TIB DPR (BB+/Negative)

Fitch has downgraded TIB DPR's notes by one notch to 'BB+' from
'BBB-'. The 'BB+' DPR rating reflects an unchanged three-notch
uplift from Isbank's LC IDR of 'B+'. Fitch calculates the monthly
DSCR for the programme at 52x based on the average monthly flows of
the past 12 months and 30x based on the lowest monthly flows in the
past five years.

Garanti DPR (BB+/Negative)

Fitch has downgraded Garanti DPR's notes by one notch to 'BB+' from
'BBB-'. The 'BB+' DPR rating reflects an unchanged two-notch uplift
from Garanti's LC IDR of 'BB-'. The notching uplift on the DPR debt
includes the consideration that Garanti's LC IDR reflects foreign
parent support. Fitch calculates the monthly DSCR for the programme
at 50x based on the average monthly flows of the past 12 months and
41x based on the lowest monthly flows in the past five years.

Yapi DPR (BB+/Negative)

Fitch has downgraded Yapi DPR's notes by one notch to 'BB+' from
'BBB-'. The 'BB+' DPR rating reflects an unchanged two-notch uplift
over Yapi Kredi's LC IDR of 'BB-'. The notching uplift on the DPR
debt includes the consideration that Yapi Kredi's LC IDR reflects
foreign parent support. Fitch calculates the monthly DSCR for the
programme at 56x based on the average monthly flows of the past 12
months and 30x based on the lowest monthly flows in the past five
years.

VB DPR (BB+/Negative)

Fitch has downgraded VB DPR's notes by one notch to 'BB+' from
'BBB-'. The 'BB+' DPR rating reflects an unchanged two-notch uplift
over Vakifbank's LC IDR of 'BB-'. The notching uplift on the DPR
debt includes the consideration that Vakifbank's LC IDR reflects
state support. Fitch calculates the monthly DSCR for the programme
at 35x based on the average monthly flows of the past 12 months and
17x based on the lowest monthly flows in the past five years.

Bosphorus (BB/Negative)

Fitch has downgraded Bosphorus's DPR notes by one notch to 'BB'
from 'BB+'. The 'BB' DPR rating reflects an unchanged one-notch
uplift over QNB Finansbank's LC IDR of 'BB-'. The notching uplift
on the DPR debt includes the considerations that QNB Finansbank's
LC IDR reflects foreign parent support and its relative positions,
as reflected in its GC2 score, in the Turkish banking sector. Fitch
calculates the monthly DSCR for the programme at 52x based on the
average monthly flows of the past 12 months and 18x based on the
lowest monthly flows in the past five years.

DFS (BB/Negative)

Fitch has downgraded DFS's DPR notes by one notch to 'BB' from
'BB+'. The 'BB' DPR rating reflects an unchanged one-notch uplift
from Denizbank's LC IDR of 'BB-'. The notching uplift on the DPR
debt includes the considerations that Denizbank's LC IDR reflects
foreign parent support and its relative positions, as reflected in
its GC3 score, in the Turkish banking sector. Fitch calculates the
monthly DSCR for the programme at 157x based on the average monthly
flows of the past 12 months and 78x based on the lowest monthly
flows in the past five years.

ISTANBUL TAKAS: Fitch Downgrades LT IDR to BB-, Outlook Negative
----------------------------------------------------------------
Fitch Ratings has downgraded Istanbul Takas ve Saklama Bankasi
A.S.'s Long-Term Issuer Default Ratings to 'BB-'. At the same time,
Fitch has revised Takasbank's Support Rating Floor to 'BB-' from
'BB'. The Outlook on the IDRs is Negative.

The rating action follows the downgrade of Turkey's sovereign
rating ('Fitch Downgrades Turkey to 'BB-'; Outlook Negative') and
the subsequent downgrade of the IDRs of Turkey's largest banks
('Fitch Downgrades 14 Turkish Banks; Outlook Negative').

KEY RATING DRIVERS

IDRs, SUPPORT RATING AND SRF

The downward revision of Takasbank's SRF to 'BB-' and the
corresponding downgrade of the bank's Long-Term IDRs to 'BB-'
reflect the sovereign downgrade, indicating the government's weaker
ability to provide support. The SRF, which underpins Takasbank's
Long-Term Foreign Currency IDR, is now at the same level as the
sovereign's Long-Term Local-Currency IDR. The Negative Outlook
reflects that of the sovereign rating.

Takasbank's Support Rating of '3' and SRF of 'BB-' reflect its view
of a moderate probability of support from the Turkish sovereign in
case of need. In its opinion, Takasbank has exceptionally high
systemic importance for the Turkish financial sector and contagion
risk from its default would be considerable given its
inter-connectedness. The state's ability to provide extraordinary
foreign-currency support to the banking sector, if required, may be
constrained by limited central bank reserves (net of placements
from banks) and the banking sector's sizable external debt.

However, in its view, the foreign-currency support needs of
Takasbank in even quite extreme scenarios should be manageable for
the sovereign. This is because of Takasbank's business model,
short-term and largely matched balance sheet, negligible external
obligations as well as acceptable liquidity position.

The Viability Rating (VR) of Takasbank is unaffected by the
sovereign downgrade as the VRs of its main counterparties -
remained unchanged, mostly at the 'b+' level.

Takasbank is Turkey's only central counterparty clearing (CCP)
institution and is majority-owned by Borsa Istanbul, Turkey's main
stock exchange. Borsa Istanbul in turn is majority-owned by the
Turkish government (via the Turkish Wealth Fund). Takasbank is
operating under a limited banking licence, and is regulated by
three Turkish regulatory bodies: the Central Bank of Turkey, the
Banking Regulation and Supervision Agency and the Capital Markets
Board.

RATING SENSITIVITIES

IDRs, SUPPORT RATING AND SRF

Rating actions on Turkey's sovereign rating are likely to be
mirrored in Takasbank's IDRs with knock-on consequences for the
Support Rating and SRF given the strong correlation of the bank's
credit profile with sovereign, country and banking sector risks.
While viewed as unlikely, changes to the systemic importance and
the role of Takasbank would lead to a reassessment of its linkages
with the sovereign rating.

Takasbank's VR is primarily sensitive to further deterioration in
the credit quality of the bank's counterparties. In addition,
Takasbank's VR remains sensitive to a material operational loss, or
a materially increased risk appetite, for example, by growing
rapidly in untested asset classes.
Increasing risk appetite in the bank's treasury activities,
particularly to lower credit-quality counterparties could also be
rating-negative as would be a decrease of the regulatory total
capital ratio below 12% (before potential forbearance).

The rating actions are as follows:

Takasbank

Long-Term Foreign-Currency IDR: downgraded to 'BB-' from 'BB';
Outlook Negative

Short-Term Foreign-Currency IDR: affirmed at 'B'

Long-Term Local-Currency IDR: downgraded to 'BB-' from 'BB+';
Outlook Negative

Short-Term Local-Currency IDR: affirmed at 'B'

Support Rating: affirmed at '3'

Support Rating Floor: revised to 'BB-' from 'BB'



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

HARLAND & WOLFF: In Talks with Potential Buyers, Future Uncertain
-----------------------------------------------------------------
Business Sale reports that the Harland and Wolff shipyard in
Belfast will not be able to survive past the end of July if a buyer
doesn't come forward, according to Unite the Union.

The business was originally put up for sale at the end of last year
as a result of serious financial issues stemming from its Norwegian
parent company, Business Sale recounts.

The shipyard, which currently employs around 130 people, is thought
to have held a series of meetings with a number of potential
buyers, as well as with union reps, Invest NI and a number of
senior political figures, in a bid to tackle its financial issues
and move forward, Business Sale discloses.

According to Business Sale, a Harland and Wolff spokesman, said the
firm has also completed all necessary legalities and is firmly in
place to proceed should a buyer emerge.

Unions are certain that the shipyard could turn around its
financial issues should it win the chance to work on the Royal
Navy's new Type 31e frigate, Business Sale states.  However, this
will not be possible until a new owner is in place, Business Sale
notes.


NOVARI LIMITED: Jailed Restaurateur Banned After GBP1MM Tax Fraud
-----------------------------------------------------------------
A jailed restaurateur was banned from running companies for 12
years after he was found to owe HM Revenue and Customs (HMRC) over
GBP1 million.

Lam Chin Seong (61), from Barnet, was the sole director of Novari
Limited and Novari (at the O2) Limited.

Incorporated in 2012, the two companies traded as the Water Margin
Chinese Restaurant in Portsmouth, as well as the Water Margin
Chinese Restaurant and Water Margin Jazz Club in Greenwich.

Each company had an annual turnover in excess of GBP1 million. Lam
Chin Seong, however, registered the companies falsely with HMRC,
describing them as arts-based businesses with estimated annual
turnovers of GBP10,000 and GBP80,000, which were significant
under-valuations.

He then failed to file VAT returns for either company, which caused
HMRC to raise assessments on the companies' behalf based on their
falsely declared annual turnovers. The assessments were, as a
result, for much smaller amounts than was really owed--sometimes
only for hundreds of pounds.

Lam Chin Seong caused the companies to pay the smaller assessments
rather than correcting the error, which meant over GBP1 million in
tax went unpaid over four-and-a-half years.

In July 2016, an HMRC investigation uncovered the fraud, and the
restaurants ceased to trade soon after. Lam Chin Seong put both
companies into liquidation in winter 2016 and autumn 2017,
respectively.

In November 2018, Lam Chin Seong pleaded guilty to two counts of
being knowingly concerned in fraudulent evasion of VAT. He was
sentenced to three years in prison in December 2018.

HMRC then worked with the Insolvency Service to secure Lam Chin
Seong's disqualification as a director in addition to his custodial
sentence.

In June 2019, the Secretary of State accepted a disqualification
undertaking from Lam Chin Seong for 12 years. Effective from July
3, 2019, Lam Chin Seong is banned from directly or indirectly
becoming involved, without the permission of the court, in the
promotion, formation or management of a company.

David Brooks, Chief Investigator for the Insolvency Service, said:

"Lam Chin Seong demonstrated a wilful disregard for the tax
authorities and a 12-year ban prevents him from using limited
liability to carry on his business practice in such a way.

"This case illustrates the excellent day-to-day relationship the
Insolvency Service has with HMRC, and we will continue to work with
our partners to prevent misconduct."

SELECT: Owes Creditors GBP53MM After Collapse
---------------------------------------------
Evening Express reports that creditors for collapsed high street
retailer Select have claimed to be owed more than GBP53 million as
part of the firm's administration.

Unsecured creditors, who include landlords and HMRC, have said they
are owed GBP53.1 million from the firm after it became insolvent in
May, the report discloses.

Evening Express says the fashion chain slid into administration
after a sharp downturn in sales in 2018, with the company failing
to hit sales targets for the period.

According to Evening Express, Select negotiated major rent cuts
with landlords last year through a company voluntary arrangement
(CVA), but it was unable to sufficiently steady the company's
precarious financial situation.

It secured a second rent cut through a CVA last month as part of
the administration process.

Evening Express, citing a statement of affairs for the retailer by
administrator Quantuma, discloses that landlords are looking to
reclaim almost GBP3.5 million from the retailer as part of the
unsecured non-preferential claims.

The document, released on Companies House, also revealed claims of
more than GBP2.3 million from Her Majesty's Revenue & Customs
(HMRC), including GBP1.7 million in relation to unpaid VAT, Evening
Express relays.

The company, which has 169 stores and employs roughly 1,800 staff,
was bought out of administration by Turkish entrepreneur Cafer
Mahiroglu in 2008, the report says.

Mr. Mahiroglu's company, Ozdemir, is owed GBP2.9 million as part of
the administration.

According to the statement of affairs, Select only had GBP1 million
of cash in the bank at the time of the administration and held a
further GBP2.8 million worth of stock, Evening Express notes.

Evening Express adds that Select, the trading name of company Genus
UK, said that trading was in line with expectations following its
first CVA in April 2018, but saw sales dive in the second half of
the year.

It reported a "highly disappointing" Black Friday followed by poor
festive sales prior to Christmas which were around 20% below its
targets.

Revenues remained "notably below forecasts" in 2019 amid continued
pressure on the high street, with Select blaming Brexit as a
"contributing factor" to the retail malaise, Evening Express
relays.

In the four months to March 31, the clothing business reported a
turnover of GBP21.4 million, and reported a loss of GBP1.3 million,
Evening Express discloses.

According to Evening Express, the company said that while Ozdemir
remained supportive, a tightening of Turkish legislation restricted
the amount of financial support it could provide the retail
business.

Select, which has an annual turnover of GBP77 million, posted a
GBP15.5 million loss for the 18 months to December 2017, Evening
Express discloses.

TOM HALL'S: Financial Difficulty Prompts Liquidation, Closure
-------------------------------------------------------------
Jenny Kirkham at Liverpool Echo reports that Tom Hall's Tavern
Ltd., a popular city centre sports bar, has closed after going into
liquidation.

According to Liverpool Echo, Tom Hall's Tavern shut its doors for
the final time after falling into financial difficulty.

"As from Saturday, July 20, 2019 Tom Hall's Tavern LTD company
number 09708753 ceased trading and went into voluntary
liquidation," Liverpool Echo quotes a notice as saying.  "Any
queries please contact Stuart Rathmell Insolvency 01204867615."


WESTON ELECTRICAL: Cash Flow Issues Prompt Administration
---------------------------------------------------------
Business Sale reports that Weston Electrical Services has gone into
administration due to "severe" cash flow issues caused, among other
reasons, by the loss of a key contract at the beginning of the
year.

According to Business Sale, the firm, based in Weston Super Mare,
said a number of financial issues also arose as a result of
"unfavorable" contract terms with clients, which caused a period of
difficult trading that spanned the first half of 2019.

Andrew Sheridan and Geoff Rowley of Bristol-based business advisory
firm FRP Advisory have been appointed administrators for the
electrical company and are now responsible for winding up the
business, which they say has incurred "substantial losses" over the
past seven months, Business Sale relates.

While all other businesses within the Incentive FM Group are
operating as normal, the 17 employees within the electrical firm
have now been made redundant while FRP Advisory search for a buyer
for the business, Business Sale discloses.


WOODFORD EQUITY: Investors Unlikely to Access Cash Until December
-----------------------------------------------------------------
Harriet Russell and Michael O'Dwyer at The Telegraph report that
investors blocked from Neil Woodford's equity income fund are
unlikely to be unable to access their cash until early December,
according to the latest update from fund supervisor Link.

The fund was suspended on June 3 after Kent County Council tried to
pull its GBP263 million stake, and has been subject to a rolling
28-day review process ever since, The Telegraph relates.

According to The Telegraph, in a letter to investors published on
July 29, Link said a December deadline for the fund to re-open gave
Mr. Woodford a "realistic" amount of time to re-position the
portfolio and improve liquidity, following close consultation with
fund depositary Northern Trust and Woodford Investment Management.

Woodford Investment Management said the move would "ensure
investors' interests are protected", notes the report. "It affords
Neil and the team the required time to execute the changes to the
portfolio that we have outlined previously," it added.

As reported by the Troubled Company Reporter-Europe on June 5,
2019, The Telegraph related that trading of Mr. Woodford's flagship
Equity Income fund was suspended due to high levels of withdrawals
from investors.  According to The Telegraph, the GBP3.7 billion
fund suffered heavy outflows since its assets peaked at GBP10.2
billion in June 2017--with GBP560 million pulled out of the fund in
the last month alone.  It has been among the worst performing
income funds since it peaked in 2017 and for investors that bought
at the launch positive returns made at the start have been all-but
wiped out, The Telegraph noted.


                           *********


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

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

Copyright 2019.  All rights reserved.  ISSN 1529-2754.

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

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

The TCR Europe subscription rate is US$775 per half-year,
delivered via e-mail.  Additional e-mail subscriptions for
members of the same firm for the term of the initial subscription
or balance thereof are US$25 each.  For subscription information,
contact Peter Chapman at 215-945-7000.


                * * * End of Transmission * * *