---

       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

          Wednesday, September 22, 2021, Vol. 22, No. 184

                           Headlines



F R A N C E

GROUPE ECORE: Fitch Raises LT IDR to 'B', On Watch Negative


G E O R G I A

GEORGIA: Moody's Affirms 'Ba2' LongTerm Issuer Ratings


G R E E C E

EUROBANK SA: Moody's Upgrades LongTerm Deposit Rating to B2


I R E L A N D

DILLON'S PARK: Fitch Assigns Final B-(EXP) Rating on Class F Debt
DILLON'S PARK: S&P Assigns Prelim. B- Rating on Cl. F Notes
SUEK SECURITIES: Fitch Gives Final BB on Guaranteed USD500MM Notes


K A Z A K H S T A N

FINCRAFT GROUP: S&P Raises LongTerm ICR to 'BB-', Outlook Stable
[*] S&P Takes Various Actions on Kazakh Financial Institutions


L U X E M B O U R G

BREEZE FINANCE: Fitch Lowers Rating on Class B Bonds to 'C'


N E T H E R L A N D S

GOODYEAR EUROPE: Fitch Rates Proposed EUR300MM Unsec. Notes 'BB-'
GOODYEAR EUROPE: Moody's Rates New EUR300MM Unsecured Notes 'Ba3'
GOODYEAR EUROPE: S&P Rates New EUR300MM Sr. Unsecured Notes 'BB-'
TCG ACQUISITIONCO: Moody's Assigns First Time 'B2' CFR
TCG ACQUISITIONCO: S&P Assigns 'B' LongTerm ICR, Outlook Stable



P O R T U G A L

ULISSES FINANCE 2: Moody's Ups EUR3.7MM E Notes Rating to (P)Ba3
VIRIATO FINANCE 1: Moody's Affirms (P)B2 Rating on Class E Notes


R U S S I A

CREDIT BANK: Fitch Gives  Final 'BB' on USD500MM Unsec. Eurobond


U N I T E D   K I N G D O M

BULB: Seeks Bailout to Stay Afloat Amid Surging Gas Prices
CHESHIRE PLC 2021-1: S&P Assigns B Rating on Class F Notes
DOWSON PLC 2019-1: S&P Affirms 'BB+' Rating on Class D Notes
FUTURE RENEWABLES: Enters Administration, Turbines Up for Sale
NORTHERN PROVIDENT: Enters Creditors' Voluntary Liquidation

PTS ACADEMY: Enters Liquidation Following Financial Woes
[*] UK: Energy Companies Collapse Due to Surging Gas Prices

                           - - - - -


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

GROUPE ECORE: Fitch Raises LT IDR to 'B', On Watch Negative
-----------------------------------------------------------
Fitch Ratings has upgraded Groupe Ecore Holdings S.A.S.'s (Ecore)
Long-Term Issuer Default Rating (IDR) and senior secured notes to
'B' from 'B-' and has placed the ratings on Rating Watch Positive
(RWP). The Recovery Rating for the senior secured notes is 'RR4'. A
full list of rating actions is detailed below.

The upgrade reflects fading risks from the coronavirus pandemic and
forecast free cash flow (FCF) on average of close to EUR15 million
per annum over the next four years. This will allow the group to
reduce net debt over time to around EUR200 million (excluding
leases, but including factoring, in accordance with Fitch's
criteria), while maintaining funds from operations (FFO) gross
leverage at 5.5x-6.0x. Fitch's financial forecast is based on its
expectation that commodity markets will moderate over the medium
term towards mid-cycle, supported by economic stimulus and
decarbonisation policies.

The RWP is pending the acquisition of Ecore by Derichebourg S.A.
(BB/Positive). Ecore's rating could benefit from Fitch's assessment
of the linkage with its future parent under Fitch's Parent and
Subsidiary Linkage (PSL) Rating Criteria.

KEY RATING DRIVERS

Economic Recovery Boosts Earnings: Fitch forecasts EBITDA for the
financial year to September 2021 (FY21) at EUR109 million (after
deducting right-of-use asset depreciation and interest on leases as
operating expense), before declining towards EUR70 million over
FY22-FY23. Strong demand from the European steel industry has
boosted margins and volumes in 2021, but Fitch expects over the
medium term margins to normalise and earnings growth to be linked
to volumes as the circular economy gains in importance.

Robust FCF; Declining Leverage Forecast: Fitch forecasts FCF on
average of close to EUR15 million per annum over the next four
years (lower in 2021 linked to a working-capital build-up and
higher thereafter as working capital is released). Improved cash
flow generation is expected to allow the group to maintain FFO
gross leverage at close to 6.0x over the medium term, with FFO net
leverage falling to a sustainable 3.5x in the short term as cash
accumulates on the balance sheet.

Scrap Market Moving Beyond Peak: Strong Turkish export rebar demand
pushed scrap prices CFR Turkey to an all-time high of USD490/tonne
or above (HMS 1/2 80:20) in May 2021. Scrap prices have since
started moderating, following the mostly completed restocking of
scrap through the value chain in Europe and Turkey, weaker steel
export demand from Asia and high freight rates. The Turkish import
price has dropped below USD440/tonne, which remains a healthy level
that will support strong availability of scrap supplies. In Europe
the CRU group expects scrap demand to increase in 2021 by 11% yoy,
before decelerating to 1% yoy by 2025.

Derichebourg Acquisition Creates Optimisation Opportunity: The
acquisition by Derichebourg remains subject to approval by
competition authorities, with a decision expected by end-2021. The
combined business will have a market share of 30%-35% of the French
metal recycling market (ferrous and non-ferrous) and some
diversification into other geographies and business services. Fitch
believes that the overall ties between Ecore and its future parent
are likely to be strong under Fitch's PSL Rating Criteria, which
supports the RWP.

Procurement Strategy Defines Margin: Ecore is a price taker in the
sale of secondary raw materials. The group uses quotes from
customers or market indices to establish maximum rates it can pay
for procurement of metal waste, defining a margin for volumes to be
processed. Its sale and procurement streams are closely
coordinated, so that commodity-price exposure can be minimised and
earnings visibility achieved. Margins for ferrous metals have
historically been more stable, with non-ferrous showing slightly
more movement over time.

Volume Risk in Downturn: If scrap prices are too low in a downturn,
available volumes from suppliers may shrink. Weak economic
conditions may lead construction and demolition companies to defer
the disposal of demolition waste, by delaying their pipeline of
projects; or cause individuals to delay the purchase of a new car,
resulting in lower volumes of end-of-live vehicles for recycling.

Supportive Market Fundamentals: EU regulation is promoting the
circular economy with an increasing emphasis on recycling. As a
result, Fitch views Ecore's business model as robust. With
recycling rates increasing over time, higher capacity utilisation
of Ecore's assets will support some earnings growth over the long
term.

DERIVATION SUMMARY

Fitch compares Ecore's business profile with that of other entities
in the wider recycling and waste sector.

Ecore's business shares common characteristics with Befesa S.A., a
services company specialising in the recycling of steel dust, salt
slag and aluminium residues. Befesa has a higher concentration of
customers on sourcing of waste materials for recycling but the
metals waste in this case is hazardous and there are fewer
companies in the market with the expertise and licence to process
the residues. Befesa also benefits from wider geographical
diversification and a more conservative financial profile. Although
Befesa hedges a large proportion of its annual zinc production, its
earnings are highly exposed to zinc prices over the long term.

Both companies reported for January to June 2020 a decline of
EBITDA by around 30%. For Ecore this was driven by lower volumes
linked to the closure of its sites in France during a
six-to-eight-week period, while margins were flat or slightly
higher. Befesa is more internationally diversified and was less
affected by lockdowns. Total volumes were broadly flat (while
production was more skewed towards steel dust and waelz oxide
compared with previous periods), but prices of recycled materials
were weaker, causing the earnings decline.

Ecore's principal and larger competitor is Derichebourg, the
leading metal recycling business in France and Spain, with smaller
operations in Mexico, Belgium, Germany, Italy and the US.

KEY ASSUMPTIONS

-- Total volumes of 3.45 million tonnes to be treated in FY21,
    increasing by a compound annual growth of 1.5% over the next
    three years.

-- EBITDA/tonne of around EUR31.5 in FY21, moderating to around
    EUR20 by FY23.

-- Negative working capital in mid double-digit millions for FY21
    linked to exceptionally high prices (after adjusting for
    movements in factoring), reversing to mid-single digit inflows
    for the following years.

-- Cash capex of around EUR25 million per annum.

-- Bolt-on acquisitions of about EUR3 million per annum.

-- No dividend payments up to FY23.

Fitch's Key Assumptions for Recovery Analysis:

The recovery analysis assumes that Ecore would be restructured as a
going-concern (GC) rather than liquidated in a default.

Our GC EBITDA estimate of EUR50 million reflects substantial
external pressures, such as a severe global downturn of Ecore's
end-markets, followed by a modest recovery. It represents Fitch's
view of a sustainable, post-reorganisation EBITDA level upon which
Fitch bases the enterprise valuation (EV).

Fitch uses a distressed enterprise value (EV)/EBITDA multiple of
5.0x to calculate a GC EV. This multiple is aligned with peers' and
also reflects Ecore's market-leading position in France, integrated
position across the recycling value chain and a well-invested asset
base.

The principal waterfall assumes that EUR52 million factoring would
be drawn in a distressed scenario (EUR104 million was the maximum
drawing under the factoring facility within the last 12 months, but
in a distressed scenario the quantum of eligible receivables would
be lower, given lower level of overall receivables linked to lower
scrap prices and most likely also lower volumes) and be taken out
of the distributable value. Ecore's EUR40 million super senior
revolving credit facility (RCF), EUR20 million
government-guaranteed loan and EUR5.5 million short-term bank debt
at operating company level also rank ahead of the group's senior
secured notes.

After deducting 10% for administrative claims, Fitch's analysis
resulted in a waterfall generated recovery computation (WGRC) in
the 'RR4' band, indicating a 'B' senior secured note rating. The
WGRC output percentage on current metrics and assumptions is 42%.

RATING SENSITIVITIES

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

-- Completion of the acquisition by Derichebourg and our
    subsequent assessment of the overall ties between Ecore and
    Derichebourg as strong;

-- Sustainable expansion of business with increased geographical
    diversification and EBITDA above EUR100 million (mid-cycle);

-- FFO gross leverage below 5x on a sustained basis (5.5x-6.0x
    forecast over the medium term);

-- FFO interest coverage above 4.0x on a sustained basis (2.8x
    3.0x forecast over the medium term).

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

-- As the rating is on RWP a negative rating action is unlikely
    at least in the short term. However, if the acquisition by
    Derichebourg falls through, the RWP is likely to be removed
    with a rating affirmation and a Stable Outlook assigned;

-- FFO gross leverage above 6.0x on a sustained basis would be
    negative for the rating;

-- FFO interest coverage below 3.0x on a sustained basis;

-- FCF below EUR10 million a year.

BEST/WORST CASE RATING SCENARIO

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

LIQUIDITY AND DEBT STRUCTURE

Comfortable Liquidity: As of 30 June 2021, Ecore held EUR128.5
million of cash on its balance sheet and its committed super senior
RCF of EUR40 million had been repaid in full and is available
(maturity in May 2023; six months ahead of the bond).

The group has little near-term maturities, linked to a EUR20
million unsecured French state-guaranteed term loan (amortising in
equal instalments by 2026) and EUR5.5 million of short-term bank
debt. Fitch forecasts FCF on average of close to EUR15 million over
the next four years and that the group will roll over its factoring
programme in the ordinary course of business. The group is funded
into 2023.

ISSUER PROFILE

Ecore is the second-largest metal recycling company in France and
has a dense network of collection sites and processing facilities.
Its broad range of services - collection, processing and sale of
ferrous and non-ferrous scrap metals - serve as competitive
advantage and allow for healthy gross margins.

SUMMARY OF FINANCIAL ADJUSTMENTS

For September 2020

-- EUR76.3 million of leases were excluded from the total debt
    amount. EUR16.8 million of depreciation and amortisation and
    EUR1.8 million of interest for leasing contracts were treated
    as operating expenditure, reducing EBITDA.

-- EUR47.8 million utilisations under Ecore's factoring programme
    were treated as debt at end-September 2020.

-- EUR26.8 million of pro-forma adjustments, linked to the
    coronavirus pandemic, reclassification of expenditure, non
    recurring items and other, were removed from EBITDA and
    instead included in non-operating/non-recurring cash flow.

-- The EUR255 million bond was included in gross debt at its
    notional, disregarding any unamortised issue premium.

-- EUR2 million of redeemable preference shares were treated as
    equity at end-September 2020. These preference shares rank
    junior to the bonds. Neither principal nor coupon will be paid
    ahead of the bond refinancing.

ESG CONSIDERATIONS

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



=============
G E O R G I A
=============

GEORGIA: Moody's Affirms 'Ba2' LongTerm Issuer Ratings
------------------------------------------------------
Moody's Investors Service has affirmed the Government of Georgia's
Ba2 local and foreign currency long-term issuer ratings and foreign
currency senior unsecured rating. The outlook remains stable.

The rating affirmation and stable outlook are underpinned by
ongoing development of the fiscal and monetary institutions which
has enabled an effective macroeconomic policy response to the
pandemic-related downturn. Structural reforms carried out during
the four-year Extended Fund Facility with the International
Monetary Fund have also helped to buttress the economy's
flexibility in response to shocks. While fiscal metrics have
deteriorated as a result of the COVID shock and the policy response
to it, fiscal consolidation accomplished ahead of the pandemic
created capacity for an effective policy response and provides a
track record suggesting that fiscal repair will occur as the impact
of the pandemic wanes. Moody's assumes that the recent political
tensions will not derail the reform agenda.

Georgia's local and foreign currency country ceilings remain
unchanged at Baa1 and Baa3, respectively. The four-notch gap
between the local currency ceiling and the sovereign rating
reflects a relatively small government footprint in the economy and
strong institutions which are predictable and reliable in terms of
policy action, notwithstanding a relatively high current account
deficit and ongoing domestic political risks that point to some
country risk. The two-notch gap between the foreign currency
ceiling and the local currency ceiling incorporates Georgia's
external vulnerabilities including a relatively high current
account deficit and still high levels of dollarization in the
economy which increase transfer and convertibility risks.

RATINGS RATIONALE

RATIONALE FOR THE RATING AFFIRMATION AT Ba2

EFFECTIVE POLICY SUPPORT LEADING TO STRONG ECONOMIC RECOVERY

Moody's expects the economy to grow by 7.3% in 2021, following a
6.2% contraction in 2020, driven by the collapse of the tourism
sector and the domestic impact of lockdowns and movement
restrictions in the wake of the pandemic. The recovery is
underpinned by fiscal policy support to consumption in 2021 and
signs of a steady rebound in regional tourism. Remittances and
non-tourism exports, such as beverages, vehicles and machinery and
equipment, have also demonstrated robust growth.

Moody's expects growth to be at potential of 4-5% in the next few
years, driven by increased investment in productivity-enhancing
infrastructure in agriculture and manufacturing, further increases
in exports to more diversified markets including Europe, partly
reflecting additions to Georgia's Free Trade Agreements, and as
incomes continue to rise supporting consumer spending.

Overall, the marked and sustained economic recovery is supported by
effective policy. While fiscal policy took up the main burden of
supporting growth during 2020, monetary policy has tightened to
contain inflation pressures driven by one-off fiscal policy changes
and a sharp depreciation of the lari, the latter reflecting the
collapse in Georgian economic activity. The recovery of the lari in
the wake of policy tightening has helped insulate the still highly
dollarised banking sector.

Moody's expects inflation to fall towards the National Bank of
Georgia's (NBG) inflation target of 3% from 12.8% currently after
temporary factors fade and tight monetary policy offsets commodity
price and international supply constraint pressures. The current
account deficit will also begin to narrow from a peak of 12.5% of
GDP in 2020 towards pre-pandemic levels of around 5%, as
remittances and non-tourism exports grow solidly and the
longer-term benefits of reforms are realized, including reform of
the pension system to build domestic savings.

FISCAL METRICS TO CONSOLIDATE AS GROWTH RECOVERS

Moody's expects Georgia's fiscal metrics to improve, following a
peak in the fiscal deficit of over 9% of GDP and increase in
general government debt to 60% of GDP in 2020, from 42% in 2019.
With a robust recovery and ongoing commitment by the government to
its fiscal framework, Moody's expects a significant number of
policies put in place to support growth to expire and revenues to
recover. As a result, Moody's expects the fiscal deficit to narrow
to around 5.3% of GDP in 2021 and just over 3% in 2022.

On the revenue side, Moody's expects revenues to rebound to 25.8%
of GDP in 2021 from a pandemic influenced trough of 25.1% of GDP in
2020 and recovering gradually towards 26.5% by 2024 as GDP growth
rate eases back to potential.

On the expenditure side, Moody's expects the expiry of a
significant number of pandemic related support programs will lower
government expenditure to around 28.5% in 2024 from a peak of 34.4%
of GDP in 2020. The key programs which will expire include the
temporary expansion of the Targeted Social Assistance program and
unemployment benefits, wages and utilities subsidies and the
pandemic related boost to healthcare spending.

Although Moody's expects general government debt to decline, it
will remain higher as a proportion of GDP than before the pandemic.
Moody's estimate of general government debt will peak at 60% of GDP
in 2020 and begin to decline towards 53% of GDP in 2024. This
compares to a pre-pandemic level of 42% of GDP in 2019. Long debt
maturities of mainly concessional borrowing limit the cost of debt.
Debt affordability will remain strong with interest payments
absorbing around 6% of revenue.

REFORM MOMENTUM TO SUSTAIN DESPITE POLITICAL TENSIONS

Ongoing frictions in Georgia's partisan political environment pose
downside risk to the credit outlook. Recently, tensions have risen
after a deal brokered by the European Parliament to resolve
differences over the October 2020 elections results was repudiated
by the Georgian Dream party. This has also raised the risk of
negative impacts on what have been the strong and effective
relationships with key technical and financial supporters in the
international and development institution communities.

At the same time, broad consensus on the need for fiscal
consolidation and further reforms remains. Reforms such as the
automation of Value Added Tax payments, and the completion of the
Extended Fund Facility (EFF) with the IMF have continued. Moody's
expects key reforms in such areas as education, the State-owned
Enterprise sector and development of the insolvency framework to
continue, even while political differences remain unresolved.

RATIONALE FOR THE STABLE OUTLOOK

The stable outlook reflects a view that the risks to Georgia's
rating are balanced. Moody's expects that the government's policy
reforms will continue to support economic growth and resilience, in
particular through greater diversification of economic activity
over time. Ongoing efforts to raise domestic savings and investment
efficiency will complement increased diversity in exports and
export markets, in part reflecting the government's logistics and
infrastructure spending plans. Moody's also expects stability in
both the domestic and geopolitical situation, notwithstanding the
domestic political frictions over much of the last 2 years.
Overall, Moody's expects an environment conducive to further
economic and institutional reforms.

These factors are balanced by still significant banking sector risk
- related to still high, albeit declining, levels of dollarisation
- and uncertainties around the extent to which the economy will see
productivity gains in key sectors such as agriculture, which has
failed to attract substantial domestic or foreign investment and
remains dominated by subsistence producers. Furthermore, despite
rising savings, Georgia's structural current account deficit and
very large net international liability position represent
significant exposure for the sovereign to potential negative turns
in external financing conditions. Demographics and an ageing
population remains a key source of social risk for Georgia's
long-term potential growth rate. Uncertainties around inflation add
to the downside risks, in light of the recent sharp increase, may
turn out to be more persistent than Moody's expect and test the
National Bank of Georgia's credibility and effectiveness.

ENVIRONMENTAL, SOCIAL, GOVERNANCE CONSIDERATIONS

Georgia's ESG Credit Impact Score is moderately negative (CIS-3),
reflecting exposure to demographic and employment challenges and,
to a lesser extent, environmental, largely physical climate, risks;
mitigated by Georgia's sustained track record of solid governance
and institutional strengths which have contributed to ongoing
increases in incomes and, together, support an capacity to respond
to social and environmental challenges.

Georgia's overall exposure to environmental risks is moderately
negative (E-3), driven by moderately negative risks related to
physical climate change, notably heat stress, exacerbated by
relatively high sensitivity related to the large size of the
agriculture sector as employer; a low proportion of the population
with access to safe water also points to environmental risks.

Moody's assesses Georgia's S issuer profile score as highly
negative (S-4), reflecting risks related to an ageing population,
high rates of youth unemployment, low incomes and only modest
spending on health and education, albeit life expectancy is
relatively high. These negative risks contrast with solid
enrollment rates in education.

Governance does not pose significant risks and Georgia's track
record suggests robust capacity to address some of the
environmental and social challenges highlighted. Georgia has had
significant success in building institutional capacity and economic
reforms which have supported flexibility in labour and product
markets, supporting moves towards higher value-added activities in
sectors like agriculture and increasing access to a broader range
of export markets.

GDP per capita (PPP basis, US$): 14,918 (2020 Actual) (also known
as Per Capita Income)

Real GDP growth (% change): -6.1% (2020 Actual) (also known as GDP
Growth)

Inflation Rate (CPI, % change Dec/Dec): 2.4% (2020 Actual)

Gen. Gov. Financial Balance/GDP: -9.3% (2020 Actual) (also known as
Fiscal Balance)

Current Account Balance/GDP: -12.5% (2020 Actual) (also known as
External Balance)

External debt/GDP: 129.4% (2020 Actual)

Economic resiliency: baa3

Default history: No default events (on bonds or loans) have been
recorded since 1983.

On September 15, 2021, a rating committee was called to discuss the
rating of the Georgia, Government of. The main points raised during
the discussion were: The issuer's economic fundamentals, including
its economic strength, have materially increased. The issuer's
institutions and governance strength, have not materially changed.
The issuer's fiscal or financial strength, including its debt
profile, has materially decreased. The issuer's susceptibility to
event risks has not materially changed.

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

FACTORS THAT COULD LEAD TO AN UPGRADE

Moody's would likely upgrade the rating if progress towards reforms
that sustainably raised domestic savings, including lifting public
saving, and reducing external vulnerability, were faster than it
currently expects. Measures that bolster the resilience of the
banking system further would also be credit positive.


Economic reforms that foster greater economic diversification and
higher productivity growth over time would raise Georgia's economic
strength and potentially support the rating.

FACTORS THAT COULD LEAD TO A DOWNGRADE

Moody's would likely downgrade the rating if there was there was a
significant sustained increase in external vulnerability risks,
notably a widening gap between domestic savings and investment, or
an escalation of geopolitical risks. A sustained deterioration in
fiscal metrics could also put downward pressure on the rating.

The principal methodology used in these ratings was Sovereign
Ratings Methodology published in November 2019.




===========
G R E E C E
===========

EUROBANK SA: Moody's Upgrades LongTerm Deposit Rating to B2
-----------------------------------------------------------
Moody's Investors Service has upgraded the long-term deposit
ratings of National Bank of Greece S.A., Eurobank S.A. and Alpha
Bank S.A. to B2 from Caa1, and Piraeus Bank S.A.'s long-term
deposit rating to B3 from Caa2. The outlook on the deposit ratings
for all four banks is positive. The rating agency has also upgraded
the long-term Counterparty Risk Assessments (CRA) of National Bank
of Greece S.A., Eurobank S.A. and Alpha Bank S.A. to Ba3(cr) from
B1(cr) and for Piraeus Bank S.A. to B1(cr) from B2(cr). The
long-term Counterparty Risk Ratings (CRR) of National Bank of
Greece S.A., Eurobank S.A. and Alpha Bank S.A. were also upgraded
to Ba3 from B2 and for Piraeus Bank S.A. to B1 from B3. The
short-term ratings for all banks were affirmed at Not-Prime (NP)
and their short-term CRA at NP(cr). Concurrently, Moody's has
upgraded the Baseline Credit Assessment (BCA) of National Bank of
Greece S.A., Alpha Bank S.A. and Eurobank S.A. to b3 from caa1, and
the BCA of Piraeus Bank S.A.'s to caa1 from caa2.

The rating action on the four largest Greek banks was primarily
driven by their improving asset quality and solvency and good
prospects for further enhancing their recurring profitability,
factors that are exerting upward pressure on their BCAs. In
addition, the upgrade to the banks' deposit ratings also reflects
their recent and upcoming MREL (minimum requirement for own funds
and eligible liabilities) eligible debt issuances until the end of
2025, which will change the banks' liability structure and enhance
the buffers available to protect depositors.

The positive outlooks reflect Moody's expectation that the four
banks will continue to improve their credit profiles, and be in a
good position to manage any new problem loan formation as a
consequence of the coronavirus pandemic. The ratings could be
upgraded in the coming quarters if the banks maintain their sound
capital and liquidity, while fully implementing their
transformation plans by further reducing their problem loans and
leveraging the economic and credit growth potential of the Greek
economy, which will benefit significantly from the EU's recovery
and resilience facility (RRF). Greece's real GDP surged by 16.2%
year-on-year in the second quarter of 2021, and will likely grow by
around 5% on average during 2021 and 2022, providing good
opportunities for banks to grow their loan books and support their
revenues.

Nonetheless, Greek banks' BCAs are still constrained by the quality
of their capital, with sizeable deferred tax credits (DTCs) in the
capital structure, and also by the challenge to further reduce
their problem loans and cost of risk, as well as improve their core
profitability by containing expenses and booking new business.

RATINGS RATIONALE

NATIONAL BANK OF GREECE S.A.

National Bank of Greece S.A.'s (NBG) deposit and CRA/CRR upgrades
are mainly driven by the upgrade in its BCA to b3 from caa1,
triggered by its improving asset quality and profitability,
combined with comfortable regulatory capital metrics. The bank's
higher BCA takes into consideration the drastic reduction of its
nonperforming exposures (NPE) ratio, being the lowest among its
local peers at 12.7% in June 2021 from 29.9% in June 2020, while
NPE provisioning coverage was the highest at approximately 67% in
June 2021. The asset quality improvement was mainly driven by a
large NPE securitization of EUR5.7 billion under the name
'Frontier', for which the bank will obtain around EUR3 billion of
senior notes guaranteed by the government under its asset
protection scheme (HAPS). The bank's rating upgrade also considers
its expectation that its NPE ratio is likely to reduce further to
around 6% by the end of 2022, on the back of more NPE
sales/securitisations and new loans in a more favourable operating
environment.

The rating agency believes that the bank's improving asset quality
will also help enhance its profitability, which has been recovering
in recent quarters. NBG reported a significant increase in profit
after tax from continued operations in the first half of 2021, at
EUR622 million from EUR465 million in the first half of 2020. This
relatively strong performance was mainly driven by lower credit
impairments, stronger core income, significant trading gains and
reduced operating expenses. Moody's believes that NBG has the
potential to further enhance its core earnings, through sustained
new lending (disbursement of new loans exceeded EUR2 billion in the
first half of 2021) and more containment of its loan loss
provisions and operating expenses, with the bank aiming to achieve
a core operating profit over average tangible equity ratio of
around 9% by the end of 2022 from an annualised 7.1% achieved in
June 2021.

Moody's said that the ratings upgrade also considers the bank's
comfortable capital position, with a reported common equity Tier 1
(CET1) ratio of 16% and a capital adequacy ratio (CAR) of 17% in
June 2021, despite the sizeable credit losses the bank has had to
take in the last few years. Moreover, the bank's capital metrics
will likely get a boost from an additional 170 basis points (bps)
once the bank officially completes its Frontier securitisation in
the fourth quarter 2021 and sells its subsidiary 'Ethniki
Insurance' that has been up for sale for some time now. The rating
agency expects the bank's fully loaded CET1 to be around 15% by the
end of 2022, which is comfortably above its current regulatory
requirement of 6.2%.

The upgrade of NBG's deposit ratings also reflects the bank's
recent and upcoming MREL-eligible debt issuances, which the rating
agency expects will enhance the buffers that are available to
protect depositors, with deposits increasing significantly by 14.1%
year-on-year as of June 2021. In October 2020, NBG issued EUR500
million of green bonds in the form of senior unsecured preferred
notes, the bank's first issuance that complies with the Single
Resolution Board's MREL. The notes were the second issuance under
NBG's EUR5 billion EMTN programme (first issuance was in July 2019
of EUR400 million Tier 2 notes) and increases Moody's confidence in
the bank's ability to issue debt and any capital instruments going
forward. Moody's expects the bank to proceed with further issuances
in the next four years, to meet its binding MREL of 26.2% of
risk-weighted assets (RWAs) by year-end 2025. Issuances will be
mostly in senior unsecured notes, as there are currently no
subordination requirements for Greek banks.

NBG's B2 deposit ratings are now placed one notch above its BCA,
from zero notches above the BCA previously, driven by the increased
protection that the rating agency expects will be afforded to
depositors from more loss-absorbing junior securities. The ratings
capture Moody's Banks Methodology, under its Advanced Loss Given
Failure (LGF) forward-looking analysis as it is applied to
countries subject to the EU's Bank Recovery and Resolution
Directive (BRRD), such as Greece.

The positive deposit rating outlook reflects the potential for
further improvements in NBG's underlying financial fundamentals in
the next 12-18 months, which will be mainly driven by lower stock
of NPEs reducing materially any downside risks to the bank's
solvency and exerting upward pressure to its BCA. The positive
outlook also considers Moody's view that the impact of the
coronavirus pandemic on the Greek economy is unlikely to leave
lasting damage, especially on tourism. This may lead the rating
agency to reassess its outlook on the operating environment and
Greece's macro profile score in the next few years, which would in
turn lead Moody's to consider a lower portion of Greek banks'
liabilities at a risk of loss in a resolution scenario.

EUROBANK S.A.

Eurobank S.A.'s (Eurobank) deposit rating upgrade is primarily
driven by its BCA upgrade to b3 from caa1 taking into account its
strong financial performance and profitability in the first
six-months of 2021, but also the significant improvement in its
asset quality, with an NPE ratio of 14% in June 2021 and prospects
to reduce it further to 7.3% by year-end once it completes its
EUR5.2 billion NPE securitisation (project Mexico) through HAPS.
Moody's said that the bank's negative NPE formation in the second
quarter 2021 combined with its annualised cost of risk (loan
impairments % net loans) of 1% and the NPE provisioning coverage of
63.3% are also positive credit drivers. Eurobank is on track to
clean up its balance sheet and continue extending new loans (loan
disbursements in Greece at EUR3.4 billion in the first half 2021),
supporting its earnings.

Eurobank S.A.'s BCA upgrade also considers Eurobank Ergasias
Services and Holdings S.A.'s ( the holding company of Eurobank
S.A.) satisfactory financial results in the first half 2021 with
net profits at EUR190 million, which provides a very good proxy for
the operating bank's performance. This was supported by a
favourable 16% year-on-year increase in its net commission income
and despite a 2.8% year-on-year decrease in its net interest income
on the back of some net interest margin (NIM) pressure (decreased
to 1.92% in June 2021 from 2.10% in June 2020). The group was able
to achieve a satisfactory 7.7% annualised return on tangible book
value as of June 2021, from 6% in June 2020.

The group's reported CET1 ratio was an adequate 13.2% in June 2021
and its CAR at 15.6%, while its fully loaded CET1 increased to
12.1% in June 2021 from 11.2% in June 2020 suggesting that the bank
has started to accumulate capital after many years of capital
consumption. Moody's also notes that under the ECB's stress-test
results announced in early August, the bank's fully loaded CET1
ratio is expected to increase further to 14.9% by the end of 2023
under the baseline scenario, increasing its loss-absorbing
cushion.

The rating agency said that Eurobank's ratings upgrade also
reflects its funding plans and existing debt issuance, in
conjunction with its MREL (26.3% of its RWAs) that has to be fully
met by the end of 2025. The bank has already a Tier 2 subordinated
bond outstanding of EUR950 million, which is fully subscribed by
the Greek government, while it also issued a senior unsecured
preferred bond of EUR500 million in April 2021, and another similar
issuance in September 2021. These bonds should be sufficient for
the bank to meet its interim MREL target of 17.8% of its RWAs by
the end of 2021. Concurrently, Moody's believes that the bank will
be in a position to continue with its issuing program over the next
four years to fully meet its final MREL, mainly in the form of
senior unsecured preferred notes. Accordingly, based on the
envisaged liability structure of the bank's balance sheet over the
next few years and on the rating agency's forward-looking LGF
analysis, the bank's deposit ratings benefit from one notch of
rating uplift from its BCA.

The positive outlook reflects the potential for further
improvements in the bank's earnings and credit profile, and also
the upside potential for its overall financial performance stemming
from the economic and credit growth potential in Greece over the
next few years. As a result, Moody's expects these factors to
likely exert upward pressure on the bank's BCA and accordingly on
its deposit and debt ratings, over the next 12-18 months.

ALPHA BANK S.A.

Alpha Bank S.A.'s (Alpha Bank) deposit rating upgrade is driven by
its BCA upgrade to b3 from caa1, which reflects its progress in
tackling its problem loans with its NPE ratio at 26% in June 2021,
down from 43% in June 2020 mainly due to its Galaxy securitisation
(NPEs of EUR10.8 billion). The NPE ratio is expected to reduce
further to 13% by year-end due to an additional NPE securitisation
of EUR3.5 billion and two NPE portfolio sales of an extra EUR3.5
billion. Moreover, Alpha Bank has plans to improve significantly
its asset quality by decreasing its NPE ratio to 2% by the end of
2024. In terms of NPE provisioning coverage, this was at 54% in
June 2021 up from 44% in June 2020, as the bank endeavours to
contain any downside risks to its solvency from its residual NPE
stock. The bank was also able to reduce its underlying cost of risk
to around 87 basis points in June 2021 from 180 basis points in
2020, although this is expected to increase to around 120 basis
points for this year.

Concurrently, the bank's BCA upgrade also captures its solid
capital position, following its share capital increase of EUR800
million in July 2021, and its stronger than peers ECB stress test
results. The operating bank's (Alpha Bank S.A.) CET1 and CAR ratios
were at 13.7% and 16.4% respectively as of June 2021. Although the
holding company's (Alpha Services and Holdings S.A.) corresponding
ratios were higher at 14.8% and 17.4% as of June 2021 (fully loaded
ratios of 12.7% and 15.4% ), these are expected to reduce following
an upcoming NPE sale (project Orbit), and accordingly should
converge with those of Alpha Bank S.A. The bank plans to
progressively increase its CET1 ratio to around 15.6% and its CAR
to around 18.3% by the end of 2024 mainly through internal capital
generation. Moody's also notes Alpha Bank's strong ECB stress test
results on a static basis and without taking into account the
recent capital increase and its Galaxy securitisation, indicating a
fully loaded CET1 ratio of 17.3% by the end of 2023 under the
baseline scenario and 8.3% under the adverse scenario, both being
the highest among its local peers.

The bank's gradually improving earnings profile is also a driving
factor of the rating action, with a normalised profit after tax of
around EUR213 million at the holding company in the first half of
2021 (EUR66 million in the first half 2020), benefiting from new
loan disbursements of EUR2.3 billion and a 14% year-on-year growth
in net fee and commission income. Nonetheless, incorporating
one-off items into the holding company's income statement, its
reported loss after tax was EUR2.3 billion, mainly due to the loss
incurred from the sizeable Galaxy securitisation. The bank aims to
achieve a return on tangible equity of around 10% by the end of
2024, compared to around 6.1% achieved in the first half 2021 on a
normalised basis and by eliminating any losses incurred from
transactions and other one-off items.

Moody's said that Alpha Bank's deposit rating upgrade also takes
into account its funding plans to fully meet its MREL (26%) by the
end of 2025 and its interim MREL target of 17.3% by the end of
2021. The bank has so far been able to tap the international
unsecured capital markets by raising a Tier 2 bond of EUR500
million in February 2020 and another similar issuance in March
2021. It also raised a EUR500 million senior preferred bond in
September 2021 as part of its commitment to meet its interim MREL,
with more MREL-eligible instruments to be issued from its operating
bank and capital instruments from its holding company to abide by
its final MREL. The rating agency's forward-looking LGF analysis
suggests that the bank's deposit ratings should be positioned one
notch higher its BCA, on the back of the protection afforded by the
pool of its loss-absorbing instruments.

The positive outlook for the bank's deposit ratings, is mainly
driven by the prospects of more upward pressure on its BCA as the
bank implements its business plan with lower NPE ratio and higher
profitability.

PIRAEUS BANK S.A.

Piraeus Bank S.A.'s (Piraeus Bank) deposit and CRA/CRR upgrades are
mainly underpinned by the bank's BCA upgrade, which takes into
consideration the NPE derisking of its balance sheet combined with
its operating efficiency and new lending that will support its core
profitability. With the on-going execution of its Sunrise plan, the
bank has brought down its absolute NPEs to EUR9 billion in June
2021 from EUR22.4 billion in December 2020, which translates into
an NPE ratio reduction to 23% from 45% respectively. The BCA
upgrade also considers the potential for further asset quality
improvements by early 2022, through a number of transactions
targeting an NPE balance of around EUR3.6 billion and an NPE ratio
of approximately 9%. The bank's track record so far provides
confidence that these plans should be successfully executed,
exerting additional upward pressure on its BCA.

The bank's BCA upgrade also considers its capital enhancing actions
in recent months amounting in total to around EUR3 billion,
including EUR1.4 billion of share capital increase in April 2021
and EUR600 million of Additional Tier 1 (AT1) capital notes in June
2021. Moody's said that although a big part of these new common
equity capital funds have been consumed to absorb losses from the
NPE securitisations, Piraeus Bank's capital metrics were
comfortably above its regulatory requirements. The bank's CET1 was
at 11.6% and its CAR at 15.8% as of June 2021, compared to the
current regulatory requirements of 6.3% and 11.3% respectively that
are likely to increase to 9.6% and 14.5% from 2023 onwards. The
intention of the bank is to maintain a CAR of around 17% going
forward through its organic capital generation, which will be
challenging in view of the bank's fully loaded CAR of 13.8% as of
June 2021 (completion of the IFRS 9 phasing is in January 2023).

Another factor driving Piraeus Bank's rating upgrade are the
favourable prospects for its underlying core profitability. The
holding company (Piraeus Financial Holdings S.A.) has shown
resilient net interest income (+6% year-on-year in the first half
2021) on the back of increasing new loans (EUR3.4 billion in the
first half 2021) and contribution from its bond portfolio, which
along with improved funding cost have offset the income attrition
from the NPE clean-up. In addition, Moody's notes the recurring
operating cost containment (-2% excluding one-off items in the
first half 2021), the significant net fee income increase of 17%
and a normalised cost of risk of 1.3% that set the foundation for
Piraeus Bank to achieve a return on tangible equity of more than
10% by the end of 2024, from a normalised 3% as of June 2021.

The bank's deposit rating upgrade is also driven by the higher
volume of loss absorbing debt instruments incorporated in the
rating agency's Advanced LGF analysis of Piraeus Bank's
forward-looking liability structure, in view of its MREL target
(26.5%) by the end of 2025. The bank already complies with its
interim MREL of 16.1% that needs to meet by the end of 2021, while
its recent track record to tap the international unsecured capital
markets through its AT1 and Tier 2 issuances from its holding
company ensure the operating bank's ability to issue more
MREL-eligible instruments over the next four years.

The bank's positive rating outlook captures potential further
improvements in its underlying financial fundamentals, especially
on its asset quality and earnings profile, benefiting from the
country's favourable economic prospects and lending opportunities
stemming from its RRF. Moody's positive rating outlook is mainly
underpinned by the upward pressure on Piraeus Bank's BCA, which
nevertheless is still positioned one notch lower that its three
local peers.

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

Over time, upward deposit and senior debt rating pressure could
arise for these banks following further improvements of the
country's macro-economic environment, which will underpin better
asset quality and profitability combined with stable capital
metrics.

Although unlikely over the short-to-medium term, Greek banks'
ratings could be downgraded in the event that their transformation
and NPE reduction plans stall, resulting in no meaningful
improvements in their recurring profitability. Any potential
deterioration in the operating environment could also have a
negative effect on the banks' ratings.

LIST OF AFFECTED RATINGS

Issuer: Alpha Services and Holdings S.A.

Upgrades:

Long-term Issuer Ratings, Upgraded to Caa1 from Caa2, Outlook
Remains Positive

Subordinate Regular Bond/Debenture, Upgraded to Caa1 from Caa2

Outlook Action:

Outlook, Remains Positive

Issuer: Alpha Bank S.A.

Upgrades:

Adjusted Baseline Credit Assessment, Upgraded to b3 from caa1

Baseline Credit Assessment, Upgraded to b3 from caa1

Long-term Counterparty Risk Assessment, Upgraded to Ba3(cr) from
B1(cr)

Long-term Counterparty Risk Ratings, Upgraded to Ba3 from B2

Senior Unsecured Regular Bond/Debenture, Upgraded to B3 from Caa1,
Outlook Remains Positive

Long-term Bank Deposit Ratings, Upgraded to B2 from Caa1, Outlook
Remains Positive

Affirmations:

Short-term Counterparty Risk Assessment, Affirmed NP(cr)

Short-term Counterparty Risk Ratings, Affirmed NP

Short-term Bank Deposit Ratings, Affirmed NP

Outlook Action:

Outlook, Remains Positive

Issuer: Alpha Group Jersey Limited

Upgrade:

BACKED Pref. Stock Non-cumulative, Upgraded to Caa3 (hyb) from Ca
(hyb)

Outlook Action:

No Outlook Assigned

Issuer: Eurobank S.A.

Upgrades:

Adjusted Baseline Credit Assessment, Upgraded to b3 from caa1

Baseline Credit Assessment, Upgraded to b3 from caa1

Long-term Counterparty Risk Assessment, Upgraded to Ba3(cr) from
B1(cr)

Long-term Counterparty Risk Ratings, Upgraded to Ba3 from B2

Long-term Bank Deposit Ratings, Upgraded to B2 from Caa1, Outlook
Remains Positive

Senior Unsecured Regular Bond/Debenture, Upgraded to B3 from Caa1,
Outlook Remains Positive

Senior Unsecured Medium-Term Note Program, Upgraded to (P)B3 from
(P)Caa1

Junior Senior Unsecured Medium-Term Note Program, Upgraded to
(P)Caa1 from (P)Caa2

Affirmations:

Short-term Counterparty Risk Assessment, Affirmed NP(cr)

Short-term Counterparty Risk Ratings, Affirmed NP

Short-term Bank Deposit Ratings, Affirmed NP

Outlook Action:

Outlook, Remains Positive

Issuer: National Bank of Greece S.A.

Upgrades:

Adjusted Baseline Credit Assessment, Upgraded to b3 from caa1

Baseline Credit Assessment, Upgraded to b3 from caa1

Long-term Counterparty Risk Assessment, Upgraded to Ba3(cr) from
B1(cr)

Long-term Counterparty Risk Ratings, Upgraded to Ba3 from B2

Long-term Bank Deposit Ratings, Upgraded to B2 from Caa1, Outlook
Changed To Positive From Stable

Senior Unsecured Regular Bond/Debenture, Upgraded to B3 from Caa1,
Outlook Changed To Positive From Stable

Subordinate Regular Bond/Debenture, Upgraded to Caa1 from Caa2

Senior Unsecured Medium-Term Note Program, Upgraded to (P)B3 from
(P)Caa1

Subordinate Medium-Term Note Program, Upgraded to (P)Caa1 from
(P)Caa2

Affirmations:

Short-term Counterparty Risk Assessment, Affirmed NP(cr)

Short-term Counterparty Risk Ratings, Affirmed NP

Short-term Bank Deposit Ratings, Affirmed NP

Outlook Action:

Outlook, Changed To Positive From Stable

Issuer: NBG Finance plc

Upgrades:

BACKED Senior Unsecured Medium-Term Note Program, Upgraded to
(P)B3 from (P)Caa1

BACKED Subordinate Medium-Term Note Program, Upgraded to (P)Caa1
from (P)Caa2

Outlook Action:

No Outlook Assigned

Issuer: Piraeus Financial Holdings S.A.

Upgrades:

Long-term Issuer Ratings, Upgraded to Caa2 from Caa3, Outlook
Remains Positive

Subordinate Regular Bond/Debenture, Upgraded to Caa2 from Caa3

Affirmations:

Short-term Issuer Ratings, Affirmed NP

Pref. Stock Non-cumulative, Affirmed Ca (hyb)

Outlook Action:

Outlook, Remains Positive

Issuer: Piraeus Bank S.A.

Upgrades:

Adjusted Baseline Credit Assessment, Upgraded to caa1 from caa2

Baseline Credit Assessment, Upgraded to caa1 from caa2

Long-term Counterparty Risk Assessment, Upgraded to B1(cr) from
B2(cr)

Long-term Counterparty Risk Ratings, Upgraded to B1 from B3

Long-term Bank Deposit Ratings, Upgraded to B3 from Caa2, Outlook
Remains Positive

Affirmations:

Short-term Counterparty Risk Assessment, Affirmed NP(cr)

Short-term Counterparty Risk Ratings, Affirmed NP

Short-term Bank Deposit Ratings, Affirmed NP

Outlook Action:

Outlook, Remains Positive



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

DILLON'S PARK: Fitch Assigns Final B-(EXP) Rating on Class F Debt
-----------------------------------------------------------------
Fitch Ratings has assigned Dillon's Park CLO DAC expected ratings.

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

DEBT                    RATING
----                    ------
Dillon's Park CLO DAC

A            LT  AAA(EXP)sf  Expected Rating
B-1          LT  AA(EXP)sf   Expected Rating
B-2          LT  AA(EXP)sf   Expected Rating
C            LT  A(EXP)sf    Expected Rating
D            LT  BBB(EXP)sf  Expected Rating
E            LT  BB(EXP)sf   Expected Rating
F            LT  B-(EXP)sf   Expected Rating
Sub Notes    LT  NR(EXP)sf   Expected Rating
X            LT  AAA(EXP)sf  Expected Rating

TRANSACTION SUMMARY

Dillon's Park CLO DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of senior unsecured,
mezzanine, second-lien loans, first-lien, last-out loans and
high-yield bonds. Net proceeds from the issuance of the notes will
be used to fund a portfolio with a target par of EUR400 million.
The portfolio is actively managed by Blackstone Ireland Limited.
The transaction has a 4.5-year reinvestment period and an 8.5-year
weighted average life (WAL).

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors in the 'B'/'B-' category. The
Fitch weighted average rating factor (WARF) of the identified
portfolio is 25.5.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise senior secured obligations. Fitch views the
recovery prospects for these assets as more favourable than for
second-lien, unsecured and mezzanine assets. The Fitch weighted
average recovery rate (WARR) of the identified portfolio is
62.79%.

Diversified Portfolio (Positive): The indicative maximum exposure
of the 10 largest obligors for assigning the expected ratings is
18% of the portfolio balance. The transaction also includes various
concentration limits, including the maximum exposure to the
three-largest Fitch-defined industries in the portfolio at 40%.
These covenants ensure that the asset portfolio will not be exposed
to excessive concentration.

Portfolio Management (Positive): The transaction has a 4.5-year
reinvestment period and includes reinvestment criteria similar to
those of other European transactions. Fitch's analysis is based on
a stressed-case portfolio with the aim of testing the robustness of
the transaction structure against its covenants and portfolio
guidelines.

Cash Flow Modelling (Neutral): The WAL used for the transaction's
stressed-case portfolio and matrices analysis is 12 months less
than the WAL covenant, to account for structural and reinvestment
conditions post-reinvestment period, including the
over-collateralisation (OC) test and Fitch 'CCC' limitation test
post reinvestment, among others. This ultimately reduces the
maximum possible risk horizon of the portfolio when combined with
loan prepayment expectations.

RATING SENSITIVITIES

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

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

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

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

-- At closing, Fitch will use a standardised stressed-case
    portfolio that is customised to the portfolio limits as
    specified in the transaction documents. Even if the actual
    portfolio shows lower defaults and smaller losses at all
    rating levels than Fitch's stressed-case portfolio assumed at
    closing, an upgrade of the notes during the reinvestment
    period is unlikely, as the portfolio credit quality may still
    deteriorate, not only by natural credit migration, but also
    through reinvestments.

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

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

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

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


DILLON'S PARK: S&P Assigns Prelim. B- Rating on Cl. F Notes
-----------------------------------------------------------
S&P Global Ratings assigned preliminary credit ratings to Dillon's
Park CLO DAC's class X, A, B-1, B-2, C, D, E, and F notes. At
closing, the issuer will issue subordinated notes.

The preliminary ratings reflect S&P's assessment of:

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

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

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

-- The transaction's legal structure, which S&P expects to be
bankruptcy remote.

-- The transaction's counterparty risks, which S&P expects to be
in line with its counterparty rating framework.

  Portfolio Benchmarks
                                                      CURRENT
  S&P weighted-average rating factor                 2,834.11
  Default rate dispersion                              534.91
  Weighted-average life (years)                          5.42
  Obligor diversity measure                            145.25
  Industry diversity measure                            22.76
  Regional diversity measure                             1.26

  Transaction Key Metrics
                                                      CURRENT
  Portfolio weighted-average rating
    derived from S&P's CDO evaluator                        B
  'CCC' category rated assets (%)                        3.67
  Actual 'AAA' weighted-average recovery (%)            35.81
  Covenanted weighted-average spread (%)                 3.65
  Covenanted weighted-average coupon (%)                 4.50

Rating rationale

Under the transaction documents, the rated notes will pay quarterly
interest unless a frequency switch event occurs. Following this,
the notes will switch to semiannual payments. The portfolio's
reinvestment period will end approximately 4.5 years after
closing.

S&P said, "We understand that at closing the portfolio will be
well-diversified, primarily comprising broadly syndicated
speculative-grade senior-secured term loans and senior-secured
bonds. Therefore, we have conducted our credit and cash flow
analysis by applying our criteria for corporate cash flow CDOs.

"In our cash flow analysis, we used the EUR396 million amortizing
target par amount, the covenanted weighted-average spread (3.65%),
the reference weighted-average coupon (4.50%), and covenanted
weighted-average recovery rates provided at each rating level. We
applied various cash flow stress scenarios, using four different
default patterns, in conjunction with different interest rate
stress scenarios for each liability rating category.

"Under our structured finance sovereign risk criteria, we consider
that the transaction's exposure to country risk is sufficiently
mitigated at the assigned preliminary ratings."

Until the end of the reinvestment period on April 15, 2026, the
collateral manager may substitute assets in the portfolio for so
long as our CDO Monitor test is maintained or improved in relation
to the initial ratings on the notes. This test looks at the total
amount of losses that the transaction can sustain as established by
the initial cash flows for each rating, and it compares that with
the current portfolio's default potential plus par losses to date.
As a result, until the end of the reinvestment period, the
collateral manager may through trading deteriorate the
transaction's current risk profile, as long as the initial ratings
are maintained.

S&P said, "At closing, we expect that the transaction's documented
counterparty replacement and remedy mechanisms will adequately
mitigate its exposure to counterparty risk under our current
counterparty criteria.

"We expect the transaction's legal structure and framework to be
bankruptcy remote, in line with our legal criteria.

"Following our analysis of the credit, cash flow, counterparty,
operational, and legal risks, we believe our preliminary ratings
are commensurate with the available credit enhancement for the
class X to E notes. Our credit and cash flow analysis indicates
that the available credit enhancement for the class B-1, B-2, and C
notes could withstand stresses commensurate with higher ratings
than those we have assigned. However, as the CLO will be in its
reinvestment phase starting from closing, during which the
transaction's credit risk profile could deteriorate, we have capped
our preliminary ratings assigned to the notes.

"Our credit and cash flow analysis shows that the class F notes
benefit from a break-even default rate-scenario default rate
(BDR-SDR) cushion that we would typically consider to be in line
with a lower rating than 'B- (sf)'. However, considering the
long-term annual default rate of 3.1% and the portfolio
weighted-average life of 5.42 years, we believe the class F notes
can sustain the steady-state scenario. We do not consider the class
F notes to be currently vulnerable to non-payment. Therefore,
following the application of our "Criteria For Assigning 'CCC+',
'CCC', 'CCC-', And 'CC' Ratings," published on Oct. 1, 2012, we
have assigned a preliminary 'B- (sf)' rating to the class F notes.

"Taking the above factors into account and following our analysis
of the credit, cash flow, counterparty, operational, and legal
risks, we believe that our preliminary ratings are commensurate
with the available credit enhancement for all the rated classes of
notes.

“In addition to our standard analysis, to provide an indication
of how rising pressures among speculative-grade corporates could
affect our ratings on European CLO transactions, we have also
included the sensitivity of the ratings on the class X to E notes
to five of the 10 hypothetical scenarios we looked at in our
publication "How Credit Distress Due To COVID-19 Could Affect
European CLO Ratings," published on April 2, 2020.

“As our ratings analysis makes additional considerations before
assigning ratings in the 'CCC' category, and we would assign a 'B-'
rating if the criteria for assigning a 'CCC' category rating are
not met, we have not included the above scenario analysis results
for the class F notes."

Environmental, social, and governance (ESG) factors

S&P said, "We regard the exposure to ESG credit factors in the
transaction as being broadly in line with our benchmark for the
sector. Primarily due to the diversity of the assets within CLOs,
the exposure to environmental credit factors is viewed as below
average, social credit factors are below average, and governance
credit factors are average. For this transaction, the documents
prohibit assets from being related to certain activities,
including, but not limited to, the following: the end manufacture
or manufacture of intended use components of biological, nuclear,
chemical or similar controversial weapons, anti-personnel land
mines, or cluster munitions; the trade in hazardous chemicals,
pesticides and wastes; ozone-depleting substances; pornography or
prostitution; predatory or payday lending activities; weapons or
firearms; tobacco; and any asset whose activities are violations of
the UNGC Ten Principles. Accordingly, since the exclusion of assets
from these industries does not result in material differences
between the transaction and our ESG benchmark for the sector, no
specific adjustments have been made in our rating analysis to
account for any ESG-related risks or opportunities."

The transaction securitizes a portfolio of primarily senior-secured
leveraged loans and bonds, and it will be managed by Blackstone
Ireland Ltd.

  Ratings List

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

  X       AAA (sf)         2.00        3mE + 0.50        N/A
  A       AAA (sf)       245.10        3mE + 1.02      38.73
  B-1     AA (sf)         22.90        3mE + 1.70      28.00
  B-2     AA (sf)         20.00              2.00      28.00
  C       A (sf)          29.00        3mE + 2.05      20.75
  D       BBB (sf)        24.00        3mE + 3.00      14.75
  E       BB- (sf)        20.00        3mE + 6.11       9.75
  F       B- (sf)         12.00        3mE + 8.64       6.75
  Subordinated  NR        31.21            N/A           N/A

  NR--Not rated.
  N/A--Not applicable.
  3mE--Three-month Euro Interbank Offered Rate.


SUEK SECURITIES: Fitch Gives Final BB on Guaranteed USD500MM Notes
------------------------------------------------------------------
Fitch Ratings has assigned Ireland-based SUEK Securities Designated
Activity Company's guaranteed USD500 million 3.375% notes a final
senior unsecured rating of 'BB'. The Recovery Rating is 'RR4'. This
follows a review of the final bond documentation, which conforms to
information received earlier.

The notes are used for the sole purpose of financing a loan to JSC
SUEK (BB/Stable) or group companies. The notes are unconditionally
and irrevocably guaranteed by SUEK and its major coal-producing
entities. Fitch views the guarantee structure as comparable to that
of SUEK's major existing debt facilities, including a pre-export
finance facility. The notes rank pari passu with all other
unsubordinated and unsecured indebtedness of SUEK.

The rating of SUEK is supported by its integrated mining, logistics
and energy-generation operations with a notable domestic market
share in each segment and its position among the leading thermal
coal exporters, its healthy margins, lower earnings volatility than
mining peers' and free cash flow (FCF) generation through the
cycle.

KEY RATING DRIVERS

Senior Unsecured Notes: SUEK is using the proceeds to refinance its
outstanding debt. The new notes leave gross debt unchanged while
improving the group's debt maturity profile and liquidity. Bond
terms are in line with market standards, including an incurrence
test at 3.5x net debt-to-EBITDA (subject to usual carve-outs),
negative pledge and limitation on mergers and transactions with
affiliates, which provide limited protection to bondholders.

Earnings Recover: Fitch expects SUEK's EBITDA in 2021 to increase
around 70% yoy to USD3 billion on the back of surge in thermal coal
prices and robust demand, together with energy-generation recovery.
As at September 2021 the group's contracted coal sales covered 100%
and 15% of export volumes for 2021 and 2022, respectively. Fitch
projects SUEK's EBITDA (IFRS16-adjusted) at mid-cycle at USD2.1
billion-USD2.2 billion.

Deleveraging Expected: Fitch expects that SUEK will use substantial
free cash flow (FCF) generated during 2021-2022 for debt reduction,
which will decrease funds from operations (FFO) gross leverage
(based on Fitch adjustments) towards 3.0x, from around 4x in
2019-2020. It has an internal covenant net debt/EBITDA target of
2x-2.5x. SUEK has headroom under its leverage sensitivities, has
demonstrated capex flexibility during downturns, and has not paid
material dividends since 2011.

Higher Leverage after Acquisitions: SUEK has in the past four years
acquired Siberian Generating Company LLC (SGK) from its
shareholder, two ports from a related party EuroChem Group AG, and
purchased other generating companies and railcar operators from
third parties. The group has spent over USD3.5 billion on
debt-funded acquisitions in this period, which transformed it into
an integrated coal, energy-generation and logistics company from a
coal miner, reducing its exposure to coal-price volatility.

Large Integrated Business: SUEK is one of the largest seaborne
thermal coal exporters globally and is the largest supplier of
thermal coal in Russia. In 2020, it exported half of its 101mt
output to the APAC and Atlantic markets. All of its export coal is
of high quality. Seventy per cent of its domestic coal sales are to
captive generating facilities. Most of SUEK's generation assets are
in Siberia, near its mining assets. The group's installed capacity
is 17.6GW, accounting for 6% of domestic electricity supply in
Russia and 20% in Siberia.

SUEK's logistics business consists of several ports and a
substantial railway fleet, mostly serving the group's coal segment.
The coal and logistics segments accounted for about two-thirds of
group EBITDA, with the remainder coming from the power division.

Stable Energy Segment: Energy sales are evenly split across
electricity, capacity and heat, and generate fairly stable cash
flow. Energy assets are consolidated under SGK. Capacity supply
agreements (CSA) cover 12% of SGK's capacities, which supports the
predictability of SGK's cash flows until 2024 when high CSA-driven
earnings end, leading to a reduction of the segment's EBITDA
towards USD600 million, from almost USD700 million in 2021-2023.
SUEK has already joined the CSA-2 programme covering another 16% of
its capacity.

Global Thermal Coal Market: Thermal coal remains a key energy
source, with a share of over 35% in global power generation. The
International Energy Agency estimated that demand for coal dropped
5% in 2020 against a 1.5% decline in energy consumption as cleaner
energy sources were prioritised. Demand is expected to recover by
2.6% in 2021 before flattening in the medium term.

Demand will grow in emerging markets, in particular in India,
Pakistan and Vietnam, where coal-fired power dominates generation,
while the share of coal in primary energy demand in China will
marginally decrease as it moves towards net zero. Given that the EU
and US now account for only 10% of global thermal coal demand,
contraction in these regions will have a limited impact on the
global market.

Energy-Transition Risks: SUEK's coal segment is exposed to
energy-transition risks. Its high-quality and low-cost coal, and
its plans to expand shipment capacities to Asia, will mitigate
reduced European demand driven by its leadership in the push for
clean energy. The group's APAC shipments vary across countries, and
benefit from the region's significant reliance on coal in
generation. SUEK's domestic market is less exposed to
energy-transition risks due to lagging regulation and a high share
of coal in the Siberian energy balance.

Competitive Cost Position: SUEK has low cash production costs,
underpinned by a high share of open-pit-mined coal, a weak Russian
rouble, and efficiency improvements. It is self-sufficient in
processing, washing and logistics infrastructure, with control over
80% of railcars and transhipment via its own ports. SUEK's mining
assets are farther from the group's export sea ports than global
mining peers', but the group's assets on average are positioned on
the lower part of the global cost curve by total business costs.

DERIVATION SUMMARY

SUEK is Russia's top thermal coal producer, operating 28 mines in
several regions, and one of the largest exporters of seaborne
thermal coal globally. SUEK has partial downstream integration into
26 coal-based and one gas turbine power plants, and operates five
sea ports and a large railcar fleet.

SUEK is comparable with AO Holding Company Metalloinvest
(BBB-/Stable) in scale and diversification, as both companies are
among the top 10 global producers of specific commodities.
Metalloinvest, which produces iron ore, has a better cost position
and higher mine life than SUEK, but the latter's operations are
more diverse, with several mines located across a number of Russian
regions, while Metalloinvest has two large mines in one region.
Metalloinvest is integrated in steelmaking, while SUEK's energy-
and power-generation segments contribute around one third to the
group's EBITDA.

PJSC Polyus (BB+/Stable) is the largest gold producer in Russia and
among the lowest-cost gold producers with an ample large reserve
base. Polyus has similar scale to SUEK but is focused only on
mining. Both Polyus and Metalloinvest have superior profitability
to SUEK, but SUEK's energy generation ensures relatively stable
cash flow. FFO gross leverage is around 2.0x-2.5x for Metalloinvest
and Polyus. SUEK's higher leverage of 3x-3.5x reflects pressure
from low thermal coal prices beyond 2021 and recent M&A
activities.

Indonesian coal peers PT Bayan Resources Tbk (BB-/Stable) and PT
Indika Energy Tbk (BB-/Negative) are smaller with slightly above
30mt thermal coal production a year each, have lower mine life,
higher concentration on one key mine and are subject to mining
concessions renewal in the next three or four years. Bayan has a
stronger cost position, higher profit margins and low leverage.
Indika has an integrated business model across mining, engineering
and construction, although its mining operations are less
profitable. Indika's rating is on a Negative Outlook due to little
leverage headroom, with FFO net leverage at or above 3x.

Another Indonesian peer is PT Adaro Indonesia Tbk (BBB-/Stable),
the second-largest Indonesian thermal coal producer, with around
60mt production expected in 2021. Adaro is integrated in mining
services and logistics. The company's parent has a joint venture
that operates two small-scale new power stations, one of which is
to commence operations in 2021. High level of integration, similar
to SUEK's, provides high flexibility and reduces earnings
volatility. Adaro's FFO net leverage is around 2x-2.5x.

KEY ASSUMPTIONS

-- Thermal coal Newcastle 6,000 kcal/kg FOB at USD115/t in 2021,
    USD87/t in 2022 and USD72/t in 2023 and USD66/t in 2024, in
    line with Fitch's mid-cycle commodity price assumptions and
    SUEK's hedges for 2021;

-- Domestic coal price growth at or slightly below rouble
    inflation to 2024;

-- Energy segment EBITDA at USD600 million-USD700 million a year
    over 2021-2024;

-- Coal sales volumes increase by high mid-single digits in 2021
    2022 on mining expansion and sales to Asia, returning to
    around 130 mt (including third-party coal) towards 2023-2024;

-- Capex around USD1 billion a year in 2021-2024;

-- USD/RUB exchange rate averaging 74.1 in 2021, 72.5 in 2022,
    and 72 in 2023-2024;

-- No dividend payment and M&A outflows (including existing
    commitments) totalling up to USD0.5 billion in 2021-2022;

-- Discretionary dividend and/or M&A outflows to result in around
    2% to 3% post-M&A FCF margin in 2023-2024.

RATING SENSITIVITIES

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

-- FFO gross leverage sustainably below 2.5x, combined with an
    extended and smoother debt maturity profile.

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

-- Subdued coal markets, aggressive dividends or M&A driving FFO
    gross leverage sustainably above 3.5x;

-- Negative FCF on a sustained basis;

-- EBITDA margin sustainably below 20%;

-- Failure to maintain liquidity ratio above 1x.

BEST/WORST CASE RATING SCENARIO

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

LIQUIDITY AND DEBT STRUCTURE

Liquidity Improves Post Transaction: At 30 June 2021 SUEK's
liquidity was tight with a reported USD1,685 million short-term
debt against an USD152 million cash balance, expected USD0.81
billion FCF over the next 12 months and USD1.05 billion unutilised
long-term committed credit facilities.

The bond issue improves SUEK's liquidity as proceeds are being used
for repayment of short-term maturities and make the group's debt
maturity profile smoother. Historically, SUEK's medium-term
liquidity position has been fragile, as the group has been reliant
on its ability to refinance the upcoming maturities of its
front-loaded debt portfolio. It also has USD0.78 billion
uncommitted long-term credit facilities.

ESG CONSIDERATIONS

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

ISSUER PROFILE

SUEK is Russia's top thermal coal producer, operating 28 mines in
several regions, and one of the largest exporters of seaborne
thermal coal globally.

SUMMARY OF FINANCIAL ADJUSTMENTS

-- Fitch has reclassified leases of USD617 million as other
    liabilities. Furthermore, Fitch has reclassified the USD168
    million of depreciation of right-of-use assets and the USD63
    million of interest on lease liabilities as lease expenses,
    reducing Fitch-calculated EBITDA by USD231 million in 2020.

-- The amount payable for the acquisition of the Tuapse and
    Murmansk bulk terminals of USD282 million was reclassified as
    debt from other payables.

-- Fitch adjusted debt by the cross-currency swap hedging
    liabilities, net of assets, of USD306 million.




===================
K A Z A K H S T A N
===================

FINCRAFT GROUP: S&P Raises LongTerm ICR to 'BB-', Outlook Stable
----------------------------------------------------------------
S&P Global Ratings raised its long-term issuer credit rating on
Fincraft Group LLP to 'BB-' from 'B+'. The outlook is stable. S&P's
'B' short-term issuer credit rating on Fincraft was affirmed.

At the same time, S&P raised its Kazakhstan national scale rating
on Fincraft to 'kzA-' from 'kzBBB'.

S&P said, "We consider that the payment culture and rule of law
have somewhat improved in Kazakhstan, reflecting steps taken to
make legal decisions more consistent and predictable. We also see
the banking sector making progress in working out problem loans and
disposing of repossessed collateral, since the secondary market for
repossessed collateral and distressed debt is becoming more active,
supported by economic recovery and tax incentives for investors in
stressed assets.

"We also believe that in recent years, Kazakhstan's authorities
have made headway in combatting corruption, including through
digitalization of services and more active judicial efforts.This
was demonstrated by an improvement in Kazakhstan's ranking on the
World Governance Indicators for control of corruption to -0.32 in
2019 from -0.82 in 2017, and modest strengthening on Transparency
International's Corruption Perception Index to No. 94 in 2020 from
No. 122 in 2017. Surveys published by Transparency International
suggest that cases of exposure to corruption have become rarer in
Kazakhstan. Although, reportedly, issues remain and the perception
of corruption remains high compared with that in developed markets
or even the regional champion Georgia, we now believe that
jurisdiction risk is not as high as before."

The global economic recovery, as well as in Russia and Kazakhstan,
is positive for Fincraft Group's investees. For instance, higher
rental rates for warehouses in Russia, along with planned dividends
from mining business on the back of higher prices for metals,
should reduce Fincraft's reliance on the sale of assets for debt
repayment.

The stable outlook reflects S&P's expectation that, over the next
12 months, Fincraft Group will not accumulate material new debt to
pursue acquisitions, and generate sufficient cash flows to meet its
outstanding obligations on bonds.

Downside scenario

S&P may take a negative rating action if:

-- Rapid accumulation of debt results in deterioration of stressed
leverage below levels S&P would consider to be very strong;

-- The group failed to dispose of assets on time, putting pressure
on cash flows; or

-- Risks from Fincraft Group's entrepreneurial ownership
materialize.

Upside scenario

A positive rating action appears to be remote at this stage, due to
the still challenging operating environment in Kazakhstan and
volatile nature of the group's operations.


[*] S&P Takes Various Actions on Kazakh Financial Institutions
--------------------------------------------------------------
S&P Global Ratings took various actions on Kazakh financial
institutions:

-- Raised its long-term issuer credit ratings (ICRs) on Halyk
Savings Bank of Kazakhstan to 'BB+/B' and national scale ratings to
'kzAA'. The outlook is stable.

-- Raised its long-term ICRs on SB Alfa-Bank JSC to 'BB/B' and
national scale ratings to 'kzA+'. The outlook is stable.

-- Affirmed the ratings on Kaspi Bank JSC at 'BB-/B' and 'kzA'.
The outlook remains positive.

-- Affirmed the ratings on ForteBank JSC at 'B+/B' and revised the
outlook to positive from stable. The national scale ratings were
raised to 'kzBBB+'.

-- Affirmed the 'B/B' ratings on brokerage subsidiaries of Freedom
Holding Corp. with stable outlooks; and affirmed the 'B-/B' ratings
on Bank Freedom Finance Kazakhstan JSC with a positive outlook.

-- Affirmed the ratings on Bank CenterCredit JSC at 'B/B' with a
stable outlook, and the raised national scale ratings to 'kzBBB-'.

-- Affirmed the ratings on Nurbank JSC at 'B-/B' and 'kzBB-'. The
outlook remains stable.

-- Affirmed the ratings on VTB Bank (Kazakhstan) at 'BB+/B' and
'kzAA'. The outlook remains stable.

Rationale

S&P said, "We believe that the impact of the long-lasting
correction phase for Kazakh banks has moderated, with banks now
benefitting from economic recovery. We forecast Kazakhstan's
economy will expand by 3.5% in 2021, supported by the government's
accommodative fiscal stance and higher oil prices and production.
The economy contracted by 2.6% in 2020, but the impact on the
banking sector was milder than we initially expected, due to banks'
only moderate lending growth in the previous years, as well as
government support measures for various categories of borrowers.
Therefore, actual systemwide credit costs in 2020 stood at
2.3%-2.5%, according to our estimates, which was significantly
below our previous expectations. We therefore believe that the
adverse impact of the long-lasting correction phase in the sector
has moderated, and now expect credit costs of about 1.5%-2.0% in
2021-2022, although we acknowledge that uncertainty remains high."

Banks have made significant progress in reducing the stock of
legacy problem loans, but there are downside risks related to
accumulation of potential new problem assets. The stock of problem
loans in the sector has reduced significantly over recent years,
due to massive write-offs of legacy problem loans in 2021, and
banks' proactive approach to collateral repossession and further
collateral sales over the past three years. Problem loans, by which
we mean Stage 3 loans and purchased or originated credit-impaired
(POCI) assets under International Financial Reporting Standards
(IFRS), had reduced to 10%-15% as of mid-year 2021 from about
20%-25% in the beginning of 2020. S&P said, "However, we
acknowledge that now the stock of nonperforming loans in the sector
is likely to remain stable, balancing further workout of the legacy
portfolio and potential recognition of problems related to the
COVID-19 pandemic, as well as banks' increasing appetite to expand
their loan books. We expect these two trends to offset each other,
although downside risks for new problem asset accumulation
persist."

S&P said, "We see that the industry structure is gradually
stabilizing. The number of banks in the sector has fallen
significantly over the past 10 years, to 23 from more than 40. This
was underpinned by the trend of polarization in the banking sector,
with stronger players increasing their market presence and weaker
players gradually leaving the market. Concentration is still high,
with the top-five banks constituting almost 70% of banking sector
assets. Contrary to previous years, we do not expect any
significant M&A or further license withdrawals. Neither do we
anticipate that technological change in banking generally or pure
tech or fintech players will result in additional competition or
profitability concerns for the local banks in the medium term. We
believe that industry structure is stabilizing and that banks will
invest in infrastructure efficiency to stay competitive. Therefore
we view the industry risk trend as positive."

Regulation and supervision remain a weakness in global context, and
improvements are to be tested as banks start to actively expand
their lending books. During previous crises in Kazakhstan, the
banking regulator tended to be reactive than proactive in dealing
with problems, resulting in several defaults of banks, including
systemically important ones, over the past decade. The systemwide
asset quality review in 2019, when the regulator assessed the
actual level of nonperforming loans and adequacy of provisioning at
the level of individual banks, was an important step in the
sector's cleanup. S&P said, "We assess governance and transparency
in Kazakhstan's banking industry as weak, mostly due to some
aspects of ownership and governance that might lead to risks.
Specifically, we believe that the business stability of many banks
is reliant on the business and political connections of their
owners. Also, banking authorities' recent steps to deepen
supervision and prevent banks from taking excessive risks are to be
tested as the banks start actively expanding their lending books.
We note that the authorities have extended until end-2021 the
period when banks are allowed to maintain the initial loan
classification for loans that were restructured due to COVID-19.
Although we understand that this refers only to the reporting under
local standards, and covers the loans that are not demonstrating
other signs of impairment, we still believe that this waiver's
extension period is longer than for other banking systems in the
region."

RATING ACTIONS ON INDIVIDUAL BANKS

Halyk Savings Bank of Kazakhstan
Primary analyst: Irina Velieva

S&P said, "We have raised the ratings on Halyk Bank to 'BB+/B' from
'BB/B', based on the bank's demonstrated resilience to adverse
operating conditions, strong track record of operating performance,
and significant progress in reducing nonperforming loans. We
believe that the improving operating environment should be
supportive for the bank's progress in maintaining its asset quality
metrics. The bank outperformed our expectations in first-half 2021,
showing an annualized return on equity of about 30%, which should
contribute to higher capital ratios than we previously expected,
depending on balance-sheet growth and dividend payout policy."

Outlook

The stable outlook on Halyk reflects S&P's expectation that the
bank will retain its market position and continue to demonstrate
strong earnings capacity in the next 12-18 months.

Upside scenario

A positive rating action is remote at this stage, since it would
require further substantial improvement in both the operating
environment and the bank's capitalization ratios, with the
risk-adjusted capital (RAC) ratio increasing sustainably above
10%.

Downside scenario

A negative rating action is also remote at this stage, but could be
taken if S&P saw the bank incurring credit losses above the system
average, or experiencing a sharp decline in profitability or
capitalization metrics.

Kaspi Bank JSC
Primary analyst: Dmitriy Nazarov

S&P has affirmed its 'BB-/B' ratings on Kaspi Bank JSC with a
positive outlook. The group's credit profile will continue to
benefit from sustainably strong earnings generation, underpinned by
a solid franchise across all platforms where it operates.

The bank's asset quality indicators continued to improve with
cost-of-risk (CoR) reducing to 1.7% at mid-year 2021 from 1.8% at
year-end 2020 and the share of problem assets (Stage 3 loans under
IFRS) reducing to 6.9% from 10.1% over the same period. The group's
risk position, therefore, could become a rating strength in the
future, especially given a high share of recurring customers and
the group's gradual strategic shift toward short-term buy-now
pay-later (BNPL) loans and merchant financing from installment
loans.

Outlook

S&P said, "The positive outlook on Kaspi Bank reflects the
possibility of an upgrade over the next 6-12 months, should we see
continuous improvement of its asset quality metrics, including
sustainably lower credit losses than domestic peers. We think asset
quality is likely to be supported by the bank's ongoing shift
toward BNPL loans and merchant financing, and away from general
purpose unsecured retail loans. The bank's improvement of its
underwriting and collection processes should also contribute."

Upside scenario

S&P could upgrade the bank in the next six months if it maintains
sustainably good asset quality indicators, at the level achieved
last year, with credit losses and nonperforming assets sustainably
lower than peers in Kazakhstan and neighboring countries. A
reduction in economic and industry risks in Kazakhstani banking
sector might also lead to an upgrade of the bank. A positive rating
action would also be contingent on management demonstrating its
ability to manage rapid growth in retail lending and payment
business, and associated operating risks, including cyber risks and
data protection.

Downside scenario

S&P said, "We could revise the outlook back to stable if recent
improvements in asset quality metrics prove to be unsustainable,
with growing credit losses and nonperforming assets. A negative
rating action may also follow if we see materialization of
nonfinancial risks, bringing financial losses or damaging Kaspi
Bank's business franchise on the domestic market." Although
unlikely, significant dividend distribution, leading to
deterioration of the bank's capital position, may also prompt a
negative rating action.

ForteBank JSC
Primary analyst: Irina Velieva

S&P said, "We have revised the outlook on ForteBank to positive
from stable and affirmed our 'B+/B' ratings due to our view that
stabilizing economic conditions and lower economic risk in
Kazakhstan as well as stabilization in the industry structure will
be beneficial for ForteBank's stand-alone credit profile (SACP). In
particular, we think that the bank will likely demonstrate more
stable asset quality with the share of Stage 3 and POCI loans to
decrease gradually to levels close to system-average of about
14%-16% in the next 12-18 months, given its moderate capital buffer
and sufficient liquidity cushion. We also think that ForteBank's
business position will remain sustainable, reflecting that it has
the fifth-largest customer franchise in Kazakhstan as well as
sustainable earnings-generation capacity. The bank's annualized
return on equity exceeded 20% for the first half of 2021."

Outlook

The positive outlook reflects S&P's assumption that ForteBank's
creditworthiness may benefit from a more supportive economic
environment and gradual stabilization of the banking sector
structure in Kazakhstan in the next 12-18 months.

Upside scenario

S&P could upgrade the ratings if it believes that the economic
environment remains supportive of ForteBank's asset quality and
profitability metrics, with the nonperforming loans ratio gradually
reducing, and the level of capitalization, as measured by our RAC
ratio, remaining at least at moderate levels.

Downside scenario

S&P could revise the outlook back to stable if the bank fails to
improve its asset quality metrics, or if the bank's capitalization
is eroded by high lending growth or substantial dividend payouts.

Bank CenterCredit JSC (BCC)
Primary analyst: Ekaterina Tolstova

S&P sid, "The affirmation of the 'B/B' global scale rating and
upgrade of the national scale to 'kzBBB-' from 'kzBB+' reflects our
view that stabilizing economic conditions and lower economic risk
in Kazakhstan has somewhat reduced pressure on BCC's stand-alone
credit profile (SACP). We consider that the bank will likely
demonstrate more stable asset quality, with the share of Stage 3
and POCI loans to decrease gradually to about 15%-17% in the next
12-18 months. We also think that BCC's business position will
remain sustainable, showing further recovery in profitability
metrics. We note that as of Sept. 1, 2021, the bank showed net
income of Kazakhstani tenge (KZT)11.5 billion and return on equity
of 12.3%. We expect that this recovery will support capital
metrics, though they will remain a relative weakness to the rating,
with the projected RAC ratio at about 4.3%-4.4% in the next 12-18
months (compared with our previous expectation of 3.6%-3.9%)."

Outlook

The stable outlook reflects S&P's view that BCC's asset quality is
gradually stabilizing on the back of the portfolio cleanup, as well
as the support measures from shareholders and the government that
are easing pressure on the bank's capital adequacy and asset
quality through the creation of additional provisions.

Upside scenario

A positive rating action appears remote in the next 12 months. It
would depend on further steps to improve BCC's asset quality and
capital position, with the RAC ratio moving sustainably above 7%.

Downside scenario

S&P said, "We could take a negative rating action in the next 12
months if, contrary to our expectations, we saw a significant
decline in BCC's capitalization, with its RAC ratio dropping below
3%. This could happen if, contrary to our expectations, we see
significant deterioration in asset quality indicators. Moreover, we
could take a negative rating action if we considered that the
government no longer regarded BCC as important to the stability of
Kazakhstan's banking sector."

SB Alfa-Bank JSC
Primary analyst: Elena Polyakova

S&P said, "We have raised the ratings on SB Alfa-Bank (ABK) to
'BB/B' from 'BB-/B' and to 'kzA+' from 'kzA', based on the bank's
demonstrated resilience to adverse operating conditions, high
profitability, and sustainably modest nonperforming assets, lower
than the system average. The share of problem assets (Stage 3 and
POCI loans under IFRS) remained at 4.0%-4.5% as of mid-year 2021
(the same as in 2019-2020) and the bank's CoR reduced to 1.6% over
the first six months of 2021 from 3% in 2020. We view positively
ABK's good underwriting standards compared with the system average
and knowledge transfer from Alfa Banking Group. We believe that the
improving operating environment should help the bank preserve its
asset quality metrics despite planned balance sheet expansion. The
bank outperformed our expectations in first-half 2021, showing an
annualized return on equity of about 31%, which should support
capital buffers amid loan book growth, depending on dividend payout
policy."

Outlook

The stable outlook reflects S&P's expectation that over the next
12-18 months ABK will sustain its better-than-system average asset
quality metrics on the back of an improving operating environment,
despite anticipated growth in what it considers riskier unsecured
consumer lending.

Upside scenario

A positive rating action would require further substantial
improvement in the operating environment and/or in the bank's
capitalization ratios, with the RAC ratio increasing sustainably
above 7%. At the same time, S&P would also expect to see a
moderation of expansion pace, while maintaining stable asset
quality. Furthermore a positive rating action would only be
possible if it improved its view on Alfa Banking Group's overall
creditworthiness.

Downside scenario

S&P said, "We might consider a negative rating action over the next
12-18 months if, contrary to our expectations, we observed that
ABK's relatively aggressive loan book growth and, in particular,
fast expansion in unsecured consumer lending had caused a
significant deterioration of its asset quality and a surge in
credit losses.

"We could also consider a negative rating action if we believed
that ABK's status within the Alfa Banking Group had weakened, and
we believed the chances of the bank benefitting from extraordinary
group support were lower. This is not our base-case scenario
though."

VTB Bank (Kazakhstan)
Primary analyst: Ekaterina Tolstova

S&P said, "We affirmed the 'BB+/B' ratings on VTB Bank (Kazakhstan)
because we consider that the bank will continue to benefit from the
wider VTB group's creditworthiness and its demonstrated strong,
long-term commitment of support if needed. In line with our
expectation, Russia-based parent VTB Bank JSC (BBB-/Stable/A-3)
retained 100% of net profits in 2020 to support future growth
prospects, which also speaks in favor of the shareholder's
commitment of support. At the same time, we do not exclude VTB Bank
(Kazakhstan) a starting to pay dividends from 2022, as the
macroeconomic environment stabilizes. However, we do not expect
this will impede the bank's growth or its capital position. We now
forecast our RAC ratio will be 5.8%-6.0% in 2021-2022, up from
4.6%-5.0% we expected previously, on the back of lower economic
risk and stabilizing industry structure. We incorporate high
lending growth of close to 15%-25% and credit costs of 2.3% of
total loans in 2021-2022, close to the market average, while the
net interest margin will remain high at about 6.8%-7.0% during the
same period."

Outlook

S&P's stable outlook on VTB Bank (Kazakhstan) mirrors that on
parent VTB Bank JSC. The rating on VTB Bank (Kazakhstan) will
likely move in tandem with that on VTB Bank JSC, reflecting its
view of group support over the next 12 months.

Upside scenario

A positive rating action on VTB Bank (Kazakhstan) is unlikely over
the next 12 months. However, if S&P was to take a positive rating
action on the parent, it would likely take a similar rating action
on VTB Bank (Kazakhstan), as long as we continue to consider it a
highly strategic subsidiary.

Downside scenario

S&P siad, "We would lower our rating on VTB Bank (Kazakhstan) if we
lowered our rating on VTB Bank JSC. Although not our base-case
scenario, we could lower the rating by two notches if we anticipate
a weakening of the parent's long-term commitment to the Kazakh
market and to its subsidiary in particular."

Nurbank JSC
Primary analyst: Ekaterina Tolstova

S&P said, "Our affirmation of the 'B-/B' ratings on Nurbank
reflects our view of a gradually improving asset quality following
support from the state and its majority shareholder. We now
anticipate the bank's RAC ratio will be about 5.2%-5.4% in the next
12-18 months, compared with 4.7%-4.8% we expected previously. In
our forecast, we envisage no capital injection in 2021-2022, a loan
book growth of about 5%-7%, and new provisioning expenses
equivalent to 3% of average total loans in the next two years. We
expect that the controlling shareholder will remain committed to
supporting the bank in case of need, in particular if there is a
need for additional provisions above our forecast."

Outlook

S&P said, "The stable outlook on Nurbank reflects our expectation
that the bank will gradually improve its asset quality and maintain
the capital adequacy buffers commensurate with its planned business
growth. We expect that the bank will also be able to maintain a
stable funding profile and sufficient liquidity buffers."

Upside scenario

An upgrade appears unlikely in the next 12 months, since it would
require significant improvement in the group's capitalization (with
RAC sustainably in our strong category), alongside further
improvement of the loan portfolio quality, and improved
profitability. An upgrade would also depend on Nurbank
demonstrating stability of overall customer deposit volume.

Downside scenario

S&P could take a negative rating action in the next 12 months if it
saw high risks to the viability of Nurbank's business, evidenced
in:

-- A significant decline in Nurbank's capitalization, with RAC
falling below 3% or regulatory ratios falling below minimum
requirement levels;

-- A material weakening in its asset-quality indicators; or

-- Pronounced pressure on its funding and liquidity metrics.

Freedom Holding Corp. and its subsidiaries
Primary analyst: Roman Rybalkin

S&P said, "We affirmed our 'B/B' ratings on brokerage subsidiaries
of Freedom Holding Corp. (IC Freedom Finance LLC, Freedom Finance
JSC, Freedom Finance Europe Ltd., and Freedom Finance Global PLC)
with a stable outlook. While further stabilization of risks in the
banking sector may have positive effects on the group's credit
profile, possibly because of stronger capital adequacy, we continue
to believe that onboarding of clients from offshore jurisdictions
would be a prerequisite for any positive rating action."

Outlook

The stable outlooks on the subsidiaries of Freedom Holding Corp.
reflect S&P's expectation that over the next 12-18 months the group
will retain its strong earnings capacity and at least moderate
capitalization, while continuing to onboard clients in onshore
jurisdictions.

Upside scenario

A positive rating action would arise only from S&P taking a more
positive view of the group's creditworthiness, which is unlikely in
the near term. Over time, tighter regulation of brokerage
activities in Russia, the complete transfer of clients under the
umbrella of Freedom Holding Corp., and at least adequate
capitalization would be prerequisites for an upgrade. The group's
performance and financial standing would also need to be assessed
relative to peers'.

Downside scenario

S&P said, "We may lower the ratings if we believe the group may
fail to maintain at least moderate capitalization. This may be due
to further acquisitions, buildup of a proprietary position in bonds
or equities, or faster-than-expected expansion of clients'
operations on the group's balance sheet. A negative rating action
may also follow if the process of transferring customers to
domestic jurisdictions stops or is reversed, or if we see rising
compliance risks from related-party transactions. We could also
lower the ratings on either of the subsidiaries if we see them as
becoming materially less important to group strategy, or if we were
less confident that they would receive group support."

Bank Freedom Finance Kazakhstan JSC
Primary analyst: Roman Rybalkin

S&P affirmed its 'B-/B' ratings on Bank Freedom Finance Kazakhstan
with a positive outlook. A positive rating action could be
triggered either if we anticipate further integration with the
group or if it believes risks of the Kazakh banking sector have
reduced further.

Outlook

The positive outlook indicates that over the next 12-18 months S&P
expects the bank to deepen its integration with the rest of the
group by offering transactional services to the group's clients.

Upside scenario

S&P could raise the rating on the bank if it sees that the group's
clientele are using its services and it becomes integral to the
group's operations in Kazakhstan. S&P may also take a positive
rating action should we see risks of the banking sector in
Kazakhstan reducing further.

Downside scenario

S&P would revise the outlook to stable if it sees limited prospects
for strengthening the bank's status within the group, for example,
if the group's strategy with respect to the bank changes.

  BICRA Score Snapshot

  Kazakhstan

                               TO           FROM
  BICRA group                   9             9
  Economic risk                 8             9
  Economic resilience           4             4
  Economic imbalances           4             5
  Credit risk in the economy    6             6
  Trend                       Positive     Stable
  Industry risk                 9             9
  Institutional framework       6             6
  Competitive dynamics          5             5
  Systemwide funding            4             4
  Trend                       Positive     Stable

Banking Industry Country Risk Assessment (BICRA) economic risk and
industry risk scores are on a scale from 1 (lowest risk) to 10
(highest risk).

  Ratings List

  BANK CENTERCREDIT JSC

  RATINGS AFFIRMED  

  BANK CENTERCREDIT JSC
   
   Issuer Credit Rating             B/Stable/B

  UPGRADED  
                                    TO           FROM
  BANK CENTERCREDIT JSC
  
   Issuer Credit Rating   
   Kazakhstan National Scale        kzBBB-/--/--   kzBB+/--/--


  BANK FREEDOM FINANCE KAZAKHSTAN JSC

  RATINGS AFFIRMED  
  
  BANK FREEDOM FINANCE KAZAKHSTAN JSC

   Issuer Credit Rating             B-/Positive/B
   Kazakhstan National Scale        kzBB/--/--


  FORTEBANK JSC
  
  RATINGS AFFIRMED; OUTLOOK ACTION  
                                   TO             FROM
  FORTEBANK JSC
   
   Issuer Credit Rating            B+/Positive/B  B+/Stable/B

  UPGRADED  
                                   TO             FROM
  FORTEBANK JSC

   Issuer Credit Rating
   Kazakhstan National Scale       kzBBB+/--/--    kzBBB/--/--


  FREEDOM HOLDING CORP.  

  RATINGS AFFIRMED  

  FREEDOM FINANCE GLOBAL PLC
  INVESTMENT CO. FREEDOM FINANCE LLC
  FREEDOM FINANCE EUROPE LTD.

   Issuer Credit Rating            B/Stable/B

  FREEDOM FINANCE JSC

   Issuer Credit Rating            B/Stable/B
   Kazakhstan National Scale       kzBB+/--/--


  HALYK SAVINGS BANK OF KAZAKHSTAN

  UPGRADED; RATINGS AFFIRMED  
                                   TO             FROM
  HALYK SAVINGS BANK OF KAZAKHSTAN

   Issuer Credit Rating            BB+/Stable/B     BB/Stable/B

  UPGRADED  
                                   TO             FROM
  HALYK SAVINGS BANK OF KAZAKHSTAN
  
   Issuer Credit Rating
   Kazakhstan National Scale       kzAA/--/--       kzA+/--/--


  KASPI BANK JSC

  RATINGS AFFIRMED  

  KASPI BANK JSC

   Issuer Credit Rating            BB-/Positive/B
   Kazakhstan National Scale       kzA/--/--

  NURBANK JSC

  RATINGS AFFIRMED  
  
  NURBANK JSC

   Issuer Credit Rating            B-/Stable/B
   Kazakhstan National Scale       kzBB-/--/--


  SB ALFA-BANK JSC

  UPGRADED; RATINGS AFFIRMED  
                                   TO             FROM
  SB ALFA-BANK JSC

  Issuer Credit Rating             BB/Stable/B    BB-/Positive/B

  UPGRADED  
                                   TO             FROM
  SB ALFA-BANK JSC

   Issuer Credit Rating
   Kazakhstan National Scale       kzA+/--/--     kzA/--/--

  VTB BANK JSC

  RATINGS AFFIRMED  

  VTB BANK (KAZAKHSTAN)

   Issuer Credit Rating            BB+/Stable/B
   Kazakhstan National Scale       kzAA/--/--




===================
L U X E M B O U R G
===================

BREEZE FINANCE: Fitch Lowers Rating on Class B Bonds to 'C'
-----------------------------------------------------------
Fitch Ratings has downgraded Breeze Finance S.A., (Breeze III)'s
class B bonds to 'C' from 'CC' and affirmed the class A bonds at
'CCC'.

RATING RATIONALE

The rating actions follow the approval by bondholders of the
issuer's restructuring proposal on 11 August 2021. The proposal
includes Breeze Three Energy GmbH&Co KG's intention to sell its
wind farm business combined with an early repayment of the bonds,
which entails a partial repayment of the class B bonds with a
waiver of remaining claims. The 'C' rating indicates that class B
default appears imminent and Fitch will downgrade the class B notes
to 'D' if the process successfully completes and the final proposal
materialises.

The class A notes will be fully repaid if the proposal successfully
completes. Consequently, Fitch has affirmed the class A bonds at
'CCC'. The rating reflects that default of the class A notes
remains a real possibility should the proposal not complete as
there may not be sufficient cash in the debt service reserve
account (DSRA) to service the bonds until maturity, according to
Fitch's projections.

KEY RATING DRIVERS

Aging Turbines Trigger More Maintenance — Operation Risk: Weaker

Historically, turbine availability has been high (96.0% historical
average). The project has also demonstrated improving cost control,
after initially underestimating the budget prior to entering into
the transaction. However, Fitch considers that a decrease in
availability in the coming years is likely, given that the turbines
are aging and will need more maintenance. At the same time,
operating costs are expected to increase. Fitch also views the
absence of performance incentive of the operators as credit
negative.

Initial Wind Estimates Largely Overestimated — Volume Risk:
Weaker

The initial wind study grossly overestimated Breeze III's wind
resources. Fitch now considers historical data a more reliable
basis for Fitch's volume projections, as a result of the actual
wind yield repeatedly falling short of expectations.

Merchant Exposure after FIT periods — Price Risk: Midrange

The wind farms are remunerated through fixed feed-in-tariffs
embedded in German and French energy regulations. German tariffs
are set for 20 years and French tariffs for 15 years. This leaves
the project with a degree of exposure to merchant pricing in the
last years before debt maturity. After the end of the
fed-in-tariffs, the wind farms receive merchant revenues until the
end of the asset life.

Partially Depleted DSRA on Class A — Debt Structure: Midrange

The class A bonds rank senior, are fully amortising and also have a
fixed interest rate. However, equally sized semi-annual principal
repayments ignoring summer and winter wind seasonality weaken the
structure. The low volumes have affected the project's liquidity,
which remains tight. Fitch does not expect it to materially
improve.

Several drawdowns on the DSRA have occurred, meaning that debt
service can still be maintained to an extent during weak wind
seasons but the reserve is eroded at EUR7.5 million versus the
initial balance of EUR14.1 million. A full replenishment of this
reserve is very unlikely, as it is subordinated to the repayment of
the entire balance of deferrals on the class B bonds. Additional
drawings on the class A DSRA would further affect the debt
structure.

Large Amounts of Deferrals on Class B — Debt Structure: Weaker

The class B DSRA is depleted and large amounts of scheduled
payments on the class B bonds have repeatedly been deferred over
the years. Although some deferrals were able to be repaid
occasionally, Fitch expects that further deferrals will accrue over
the coming years. They may be repaid until the class A bonds reach
their maturity, but the subordination to the class A makes this
scenario unlikely.

Financial Profile

Fitch's base and rating cases are based on historical average
production. Fitch's rating case also includes an additional 15%
stress on costs. Fitch's rating case results in average and minimum
annual debt service coverage ratios of 1.28x and 0.78x (average of
0.86x until 2023), respectively, for the class A bonds and
highlight that there is little financial cushion, mainly because
the equally sized semi-annual principal repayments ignoring summer
and winter wind seasonality mean that there is less cash available
for the autumn debt service. This increases the likelihood of
further drawdowns on the class A DSRA, already partially depleted.
Fitch concludes that there may not be sufficient cash in the
reserve to service the class A until maturity, positioning the
rating at 'CCC'.

PEER GROUP

Like Breeze III, CRC Breeze Finance SA (Breeze II) financed a
portfolio of onshore wind farms predominately located in Germany,
and to a lesser extent in France. As a result, the wind farms share
the same regulatory framework, with fixed feed-in-tariffs. They
have equally suffered from severe overestimation of their wind
resources and from the subsequent underperformances as a result.
Additionally, the seasonality of wind yield combined with equal
semi-annual principal repayments has led to shortfalls at the
autumn payment dates. This has resulted in deferrals on the class B
and drawings on the class A DSRA for both transactions.

For Breeze III the class B bonds mature in 2027. For Breeze II, the
scheduled maturity is 2016 and the payments can be deferred until
the class A bonds reach their maturity in 2026. However, Fitch does
not see a significant benefit in this feature, as the high number
of deferrals and their subordination to the class A are coupled
with a full depletion of the class B DSRA. This means that a full
repayment of the class B bonds is highly unlikely.

Fitch believes that the ratings of the two transactions should be
aligned as a result at 'CCC' for the class A. For Breeze III, the
ongoing restructuring process, which would result in a haircut at
class B drives the rating at 'C' whereas it is 'CC' for Breeze II.

RATING SENSITIVITIES

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

-- Class A: Weak wind conditions, a material decline in
    availability or a lasting increase in operating costs
    triggering further significant drawdowns on the class A DSRA.

-- Class B: The implementation of the final proposals as accepted
    by bondholders will result in a downgrade of the class B bonds
    to 'D'.

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

-- An upgrade of either class at this point appears unlikely.

BEST/WORST CASE RATING SCENARIO

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

CREDIT UPDATE

Performance Update

Further significant drawdowns have been made on the class A DSRA
over the past 12 months to meet debt service repayments, due to
poor wind conditions. The class A DSRA balance is currently at
EUR7.5 million, compared with an initial balance of EUR14.1
million. The class B DSRA has been fully depleted and the balance
of total class B deferrals currently stands at 72% of the class B
bonds' notional amount.

FINANCIAL ANALYSIS

Fitch Cases

Fitch's base and rating cases are based on historical average
revenues. This assumption changes as the project yields more
historical data. Fitch's rating case also includes an additional
15% stress on costs.

ESG CONSIDERATIONS

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




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

GOODYEAR EUROPE: Fitch Rates Proposed EUR300MM Unsec. Notes 'BB-'
-----------------------------------------------------------------
Fitch Ratings has assigned a rating of 'BB-'/'RR4' to Goodyear
Europe B.V.'s (Goodyear Europe) proposed issuance of EUR300 million
in senior unsecured notes. Goodyear Europe intends to use proceeds
from the notes to redeem its EUR250 million of 3.75% senior
unsecured notes due 2023, with remaining proceeds used for general
corporate purposes.

Goodyear Europe is a wholly-owned subsidiary of The Goodyear Tire &
Rubber Company (Goodyear). Goodyear, along with its wholly-owned
U.S. and Canadian subsidiaries that guarantee Goodyear's secured
revolver, second lien term loan and senior unsecured notes, will
also guarantee Goodyear Europe's proposed notes.

The Long-Term Issuer Default Ratings (IDR) of Goodyear and Goodyear
Europe are 'BB-'; the Rating Outlooks are Stable.

KEY RATING DRIVERS

Ratings Overview: The IDRs of Goodyear and Goodyear Europe reflect
Fitch's expectation that the company's credit profile over the
intermediate term will fall within Fitch's ratings sensitivities,
despite some near-term pressure due to the recent Cooper Tire &
Rubber Company (Cooper) acquisition and continued external
challenges related to the ongoing coronavirus pandemic. Helping to
support Goodyear's ratings was its decision to fund a portion of
the Cooper acquisition with cash on hand and common stock, which
limited the amount of incremental debt needed to complete it.
Coupled with Cooper's somewhat stronger pre-acquisition standalone
credit profile, this resulted in only a relatively modest increase
in leverage compared with Fitch's standalone expectations for
Goodyear, and Fitch expects leverage to decline over the
intermediate term as synergies are achieved and as the company
realizes benefits from other cost savings initiatives.

Rating Risks: Despite Goodyear's Stable Outlook, a number of
potential credit risks remain. The pandemic has led to numerous
challenges to global supply chains, and although Goodyear has been
able to manage through these difficulties so far, higher costs
associated with these issues could lead to lower-than-expected
margins and FCF. A potential decrease in economic activity in
certain global regions as a result of the Delta variant could also
result in further supply chain challenges or lower levels of tire
demand in those end-markets. The tire industry also remains highly
competitive, and although the Cooper acquisition has broadened
Goodyear's product portfolio, several of Goodyear's global
competitors have stronger credit profiles and greater financial
flexibility if tire market conditions unexpectedly worsen.

Long-Term Tire Demand Fundamentals Intact: Over the long term,
Fitch expects global replacement tire shipments will grow along
with the global vehicle population. In addition, the tire
industry's shift toward larger diameter, higher technology premium
tires, especially in developing markets, will benefit those tire
manufacturers, like Goodyear, that have focused on these higher
margin products over the past decade. This shift will accelerate as
the global electric vehicle (EV) population grows, given the more
advanced tire technology requirements needed for the premium EVs
that many manufacturers will be introducing over the next few
years. Over the past several years, Goodyear has won a number of OE
fitments for EVs that it has begun supplying, particularly in
Europe.

Elevated Leverage: Fitch expects Goodyear's pro forma gross EBITDA
leverage (debt/Fitch-calculated EBITDA) will be elevated, likely in
the low-4x range, at YE 2021, but Fitch expects it to decline
toward the mid-3x range over the next two years as market
conditions normalize and Goodyear realizes synergies from the
Cooper acquisition. Fitch expects FFO leverage will also be
elevated in the near term, at around 6.0x by YE 2021, due, in part,
to lower FFO as a result of about $225 million in rationalization
payments expected in 2021, as well as near-term cash costs
associated with the acquisition. Fitch expects FFO leverage to
decline toward the low-4x range by YE 2023.

Negative Near-Term FCF: Fitch expects Goodyear's FCF will be
negative in 2021 as the company replenishes its tire inventories,
which were depleted in 2020 as the company closed plants during the
height of the pandemic. Fitch also expects FCF in 2021 will be
pressured by higher capex, as the company makes up for spending
that was deferred from 2020. Beyond 2021, Fitch expects Goodyear's
FCF to turn positive as working capital and capex normalize and as
the company begins to realize synergies from the Cooper
acquisition. Fitch expects FCF margins to run in the 1.5% to 3.5%
range over the longer term.

DERIVATION SUMMARY

Following the Cooper acquisition, Goodyear has a relatively strong
competitive position as the third-largest global tire manufacturer,
with highly recognized brands and a focus on the higher-margin
high-value-added (HVA) tire category. However, the shift in focus
has led to lower tire unit volumes and revenue, particularly in the
mature North American and Western European markets. The company's
geographic diversification is increasing as rising incomes in
emerging markets lead to higher demand for HVA tires, particularly
in the Asia-Pacific region. Product and end-market diversification
have also increased with the introduction of Cooper's tires to
Goodyear's product offering.

Goodyear's margins are roughly consistent with those of the other
large Fitch-rated tire manufacturers, Compagnie Generale des
Etablissements Michelin (A-/Stable) and Continental AG
(BBB/Stable), but Goodyear's leverage is considerably higher, as
the other two companies generally maintain midcycle EBITDA leverage
below 1.0x. Goodyear's midcycle leverage is roughly consistent with
that of auto and capital goods suppliers in the 'BB' category, such
as Meritor, Inc. (BB-/Stable). Goodyear's margins are relatively
strong compared with typical 'BB'-category issuers, but this is
tempered by seasonal working capital swings that lead to more
variability in FCF over the course of a typical year. FCF margins
are also highly sensitive to raw material costs and capex.

KEY ASSUMPTIONS

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

-- Global auto production rises by 6% in 2021, including an 8%
    increase in the U.S.;

-- Global replacement tire demand largely recovers in 2021 and
    runs near the 2019 level. Beyond 2021, demand grows at a low-
    single-digit rate;

-- Acquisition synergies ramp over the next several years and
    reach a run rate of $165 million by YE 2023;

-- Costs to achieve synergies total $170 million and are
    primarily recognized in 2021 and 2022;

-- Capex, which includes Cooper's post-acquisition capex, is
    slightly elevated in 2021 at about $1.0 billion, then runs
    near historical levels near 5% of revenue over the next
    several years;

-- FCF is negative in 2021 due to negative working capital as the
    company rebuilds depleted inventories, then runs in the 1.5%-
    3.5% range over the following years;

-- The company maintains a solid liquidity position, including
    cash and credit facility availability.

RATING SENSITIVITIES

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

-- Demonstrating continued growth in tire unit volumes, market
    share and pricing;

-- Sustained FCF margins of 1.5%;

-- Sustained gross EBITDA leverage below 3.0x;

-- Sustained FFO leverage below 3.5x.

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

-- Integration issues or unforeseen costs associated with the
    acquisition that inhibit the company's ability to bring its
    credit profile inside of its negative rating sensitivities
    within two years;

-- A significant step-down in demand for the company's tires
    without a commensurate decrease in costs;

-- An unexpected increase in costs, particularly related to raw
    materials, that cannot be offset with higher pricing;

-- A decline in the company's consolidated cash below $700
    million for several quarters;

-- Sustained break-even FCF margin;

-- Sustained gross EBITDA leverage above 4.0x;

-- Sustained FFO leverage above 4.5x.

BEST/WORST CASE RATING SCENARIO

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

LIQUIDITY AND DEBT STRUCTURE

Adequate Liquidity: Fitch expects Goodyear's liquidity to remain
adequate. As of June 30, 2021, the company had $1.0 billion in cash
and cash equivalents, excluding Fitch's adjustments for not readily
available cash, and $4.1 billion available on its various global
credit agreements, including $3.3 billion available on its primary
U.S. and European revolvers.

According to its criteria, Fitch treats $600 million of Goodyear's
cash as not readily available, based on Fitch's estimate of the
amount of cash needed to cover seasonality in the company's
business.

Debt Structure: Goodyear's consolidated debt structure primarily
consists of a mix of secured bank credit facilities and senior
unsecured notes. As of June 30, 2021, Goodyear had $400 million in
second-lien term loan borrowings and $5.0 billion in senior
unsecured notes outstanding. There were no borrowings outstanding
on Goodyear's first-lien secured revolver. Goodyear Europe's debt
structure consisted of the aforementioned senior unsecured notes
and $246 million of on-balance sheet accounts receivable
securitization borrowings. Goodyear Europe's secured revolver was
undrawn.

Goodyear also has various borrowings outstanding at certain
non-U.S. operations, including credit facilities in Mexico and
China. The Cooper subsidiary has $117 million in principal value of
senior unsecured notes outstanding that Goodyear does not guarantee
and that Fitch does not rate. (The Cooper notes were recorded at
$136 million on Goodyear's consolidated balance sheet at June 30,
2021 as a result of a fair-value adjustment made in conjunction
with the acquisition closing.)

In addition to its on-balance sheet debt, Fitch treated $518
million of off-balance sheet factoring as debt at June 30, 2021.

ESG CONSIDERATIONS

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

ISSUER PROFILE

Goodyear, headquartered in the U.S., is the third-largest tire
manufacturer in the world. The company operates globally and
manufactures tires for passenger, commercial and off-highway
vehicles, as well as aircraft. In addition to tires, Goodyear
manufactures rubber-related chemicals and operates tire retail and
service outlets. The replacement market comprises about 75% of the
company's tire unit sales, with sales to OE manufacturers making up
the remaining 25%.


GOODYEAR EUROPE: Moody's Rates New EUR300MM Unsecured Notes 'Ba3'
-----------------------------------------------------------------
Moody's Investors Service assigned a Ba3 rating to Goodyear Europe
B.V.'s proposed EUR300 million senior unsecured guaranteed notes.
Parent company The Goodyear Tire & Rubber Company's (Goodyear)
existing ratings, including the B1 corporate family rating, the
B1-PD Probability of Default rating, the Ba2 senior secured
second-lien term loan rating, the B2 senior unsecured guaranteed
notes rating, the B3 senior unsecured unguaranteed notes rating and
the SGL-2 Speculative Grade Liquidity rating are all unaffected.
The rating outlook is stable.

The proceeds from these notes are expected to be used to redeem the
existing Ba3 EUR250 million senior unsecured guaranteed notes due
2023 in a largely debt-neutral transaction.

Goodyear Europe B.V. is the primary offshore financing subsidiary
of Goodyear and has an unrated EUR800 million secured revolving
credit facility along with the EUR250 million senior unsecured
guaranteed notes to be repaid with this issuance.

Moody's took the following action on Goodyear Europe B.V.:

New Gtd. Senior Unsecured Regular Bond/Debenture, assigned at Ba3
(LGD3)

RATINGS RATIONALE

Goodyear's ratings reflect its strong global position as a
manufacturer of aftermarket and original equipment tires supported
by a leading market share position in North America, good scale and
growth in higher-margin, 17-inch and larger tires. The addition of
Cooper Tire & Rubber Company (Cooper Tire) in Q2 2021 strengthens
Goodyear's US replacement tire position while also meaningfully
boosting the original equipment tire business in China where demand
is accelerating. The acquisition increased debt-to-EBITDA
(including Moody's standard adjustments) towards 6x but should
result in annual free cash flow of over $200 million that can be
directed to debt repayment. As a result, Moody's expects
debt-to-EBITDA to fall towards 4x by year-end 2022. The EBITA
margin is expected to rebound sharply in 2021 and resume growth in
2022 as continued cost savings and distribution synergies gain
traction.

The stable outlook reflects Moody's expectations for industry tire
volumes to continue rebounding into 2022, leading to improved cost
absorption and higher margins. The combined entity should generate
strong cash flow sufficient to fund growth investments and debt
repayment while maintaining a sizable cash position and modest
reliance on revolving credit facilities.

Goodyear's SGL-2 Speculative Grade Liquidity Rating is supported by
Moody's expectation for maintenance of a robust cash position ($1
billion at June 30, 2021) and significant availability under
various revolving credit facilities. At June 30, 2021 the company
had over $2.3 billion of availability (zero drawn) under its $2.75
billion asset-based lending facility (ABL) expiring 2026 and full
availability under Goodyear Europe B.V.'s EUR800 million revolving
credit facility set to expire 2024. Moody's expects normalized
annual free cash flow to comfortably exceed $200 million even with
higher growth investments in working capital and capital
expenditures.

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

The ratings could be upgraded with improving margins, boosted by
better than anticipated savings/synergies from the Cooper Tire
acquisition. The expectation that meaningful, positive free cash
flow will be used for debt reduction such that debt-to-EBITDA falls
towards 3.5x or EBITA-to-interest eclipses 3x could also warrant
positive rating action. Ratings could be downgraded if the EBITA
margin declines to the mid-5x range, free cash flow falls well shy
of Moody's expected level or debt-to-EBITDA approaches 6x.
EBITA-to-interest below 2.5x could also result in a downgrade.
Ratings pressure could also arise from a meaningful decline in
liquidity, including increased reliance on revolving credit
facilities.

The principal methodology used in this rating was Automotive
Suppliers published in May 2021.

The Goodyear Tire & Rubber Company is one of the largest tire
manufacturers in the world. Revenue for the latest twelve months
ended June 30, 2021 was approximately $14.6 billion.


GOODYEAR EUROPE: S&P Rates New EUR300MM Sr. Unsecured Notes 'BB-'
-----------------------------------------------------------------
S&P Global Ratings assigned its 'BB-' issue-level rating and '3'
recovery rating to Goodyear Europe B.V.'s proposed EUR300 million
senior unsecured notes due 2028. The '3' recovery rating indicates
its expectation for meaningful (50%-70%; rounded estimate: 65%)
recovery for the senior unsecured lenders in the event of a payment
default.

The company plans to use the proceeds from these notes to refinance
its existing EUR250 million senior unsecured notes due 2023, with
the remainder for general corporate purposes. Because this is
largely a refinancing transaction, it will not materially increase
Goodyear's leverage or impair the recovery prospects for its
unsecured noteholders. Therefore, S&P rates the new unsecured notes
at the same level as its issue-level rating on the company's
existing senior unsecured debt.


TCG ACQUISITIONCO: Moody's Assigns First Time 'B2' CFR
------------------------------------------------------
Moody's Investors Service has assigned a B2 corporate family rating
and a B2-PD probability of default rating to TCG AcquisitionCO B.V.
the holding company at the top of the restricted group and at which
the group will provide consolidated reports going forward.
Concurrently, Moody's assigned B2 instrument ratings to the EUR315
million senior secured term loan B maturing in September 2028 and
the EUR65 million senior secured revolving credit facility maturing
in March 2028. The outlook assigned on all ratings is stable.

The proceeds from the new facilities will serve to finance TCG's
acquisition by financial sponsor Crestview from Royal Ten Cate (B2
stable).

RATINGS RATIONALE

TCG's rating positively reflects (1) its leading market position in
the upstream segment and top 10 position in the mid and downstream
segments in a very fragmented industry, (2) moderately growing end
markets at low single digits in sports and high single digits in
landscaping as artificial turf allows for increased usage and water
savings compared to natural turf; (3) vertical integration along
the value chain allow for captive intercompany sales and pull
through of margins (4) widely diversified customer base with
relatively low churn; (5) strong track record of improving
operating performance and integrating several acquired companies
over the past 5 years reflected in an EBITA-Margin of around 10%
expected for year end 2021; (6) relatively good cash generation due
to moderate working capital and maintenance capex requirements.

TCG's B2 CFR is weakly positioned considering its (1) relatively
small size with EUR471 million of revenue LTM July 2021; (2) fairly
limited product and production diversification with only 4
manufacturing plants producing artificial turf for sports and
landscape end-markets; (3) a highly competitive end markets
especially in the sports segment (about 80% of revenue in 2020) as
the lion's share of new contracts is awarded through public or
private tenders (4) execution and integration risk related to TCG's
growth strategy largely driven by continuous bolt on acquisitions;
(5) its relatively high starting leverage of 5.8x for the B2 rating
category, which Moody's expect to decline to below 5.5x over the
next 12-18 months; and (6) its modest starting cash position.

Since, 2017 RTC has followed an active buy and built strategy along
the entire artificial turf value chain and successfully acquired
and integrated about 13 small to medium size companies Hence,
Moody's expects TCG to continue to direct the lion's share of its
free cash flow to further consolidate the fairly fragmented
industry and hereby strengthen its market position. Continuous bolt
on acquisitions are likely help to deleverage the group's balance
sheet over the medium term but at the same time expose the company
to meaningful integration risk and potentially require additional
financing through the RCF.

ESG

Environmental considerations favoring synthetic turf demand are
expected to grow due to water and fertilizer savings. Furthermore,
European regulation for microplastic are likely to ban microplastic
from synthetic turf solutions from 2022 with a 6 year transition
period. This will require the industry to switch to alternative low
/ non-infill turf systems. TCG already offers alternative solutions
meeting expected regulations and expects to capture market share
from smaller competitors and low cost Asian imports.

The company is owned by the private equity firm Crestview and
management. Private equity funds tend to have higher tolerance for
leverage, a greater propensity to favor shareholders over creditors
as well as a greater appetite for M&A to maximize growth and their
return on their investment.

LIQUIDITY

Moody's deem TCG's liquidity as adequate and expects TCG's EUR65
million RCF to be drawn by about EUR10 million at closing of the
acquisition to finance day to day cash needs as post-closing of the
transaction only EUR5 million of cash will remain on balance sheet.
The rating agency expects TCG to generate about EUR20 million of
free cash flow in 2022, which is likely to redeem the drawn portion
of the RCF and to fund bolt on acquisitions on an opportunistic
basis.

The RCF has a springing net leverage covenant at 7.3 times, which
only will be tested if the RCF is drawn by more than 40%. Moody's
expects TCG to remain well below the covenant level if tested.

OUTLOOK

The outlook on all of TCG's rating is stable, reflecting Moody's
view that moderate market growth coupled with management efficiency
initiatives will help to reduce the company Debt/EBITDA to well
below 5.5x over the next 12-18 months and to generate sufficient
free cash flow to repay the RCF and built a substantial cash buffer
on its balance sheet or internally finance bolt on acquisition in
21/22.

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

An upward revision of the rating would likely result from (1)
adjusted EBITA margins reaching mid-teens; (2) Moody's-adjusted
leverage ratio declining well below 5.0x on a sustained basis and;
(3) material sustained positive cash flow generation as evidenced
by adj. FCF /debt in the high single digits in combination with an
excellent liquidity.

Downward pressure on the rating could occur if (1) adjusted EBITA
margins are not maintained at above 10% on a sustained basis; (2)
Moody's-adjusted debt/EBITDA ratio does not reduce over the next
12- 18 months to below 5.5x; and (3) if the group's liquidity
weakens as evidenced by negative free cash flow or material debt
funded acquisitions.

PRINCIPAL METHODOLOGY

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

COMPANY PROFILE

TenCate Grass Holding B.V. is a leading manufacturer, distributor
and installer of artificial turf solutions for both sports and
landscaping with reported revenues of EUR471 million in LTM July
2021. The company operates a vertically integrated business model
along the artificial turf value chain and has its headquarter in
Nijverdal in the Netherlands. It is owned by funds advised from the
US based private equity firm Crestview and by its senior
management.


TCG ACQUISITIONCO: S&P Assigns 'B' LongTerm ICR, Outlook Stable
---------------------------------------------------------------
S&P Global Ratings assigned its 'B' long-term issuer credit rating
to TCG AcquisitionCo B.V. and a 'B' issue credit rating to the
company's term loan B. The '3' recovery rating on the debt
indicates that S&P sees recovery prospects of about 50% in the
event of default.

The stable outlook indicates that S&P expects TCG will continue to
grow profitably, supported by its sales mix as they increase their
share of the market for landscaping products in Europe and thanks
to its vertically integrated business model. This translates into
debt to EBITDA of 5x in the next 12-18 months.

In July 2021, private equity firm Crestview Partners said it would
acquire TenCate Group's grass division through its TCG
AcquisitionCo B.V. entity.

TCG should benefit from growth prospects in the production of
synthetic turf for sport and landscaping applications, thanks to
its strong market position and ability to meet specific customer
requirements. S&P Global Ratings anticipates that demand for
synthetic turf will be boosted by the product's lower need for
water and lower maintenance cost compared with natural grass. This
encourages customer demand in regions that are facing water
scarcity and helps end-users realize significant cost-savings. As
technological improvements increasingly make artificial grass look
and feel more like natural grass, the use of artificial grass
becomes more acceptable to customers.

For sport applications, in particular, synthetic turf's improved
player safety and greater performance compared with natural grass
also boost demand. S&P thinks that TCG is well-positioned to
capture this demand, given its leading market position in the
production of synthetic yarn in Europe and in the U.S. In addition,
the company's ability to consistently deliver high-quality products
in terms of durability, performance, and look and feel gives the
group a competitive advantage in maintaining customer loyalty and
winning contracts in new markets. The group benefits from an
efficient network of manufacturing assets located close to its
customers in the U.S., Europe, and the Middle East. This enabled
the company to offer high levels of customer service within a short
timeframe, even during the pandemic. Overall, S&P forecasts that
the TCG group will achieve annual revenue growth of about 8%-14% in
the next 12-18 months, based on organic growth combined with
contributions from acquired businesses.

TCG's vertically integrated business model gives it full control of
the value chain and will enable it to enjoy profitable growth, in
S&P's view. The subsidiary, TenCate Grass, produces all the
synthetic yarn that it uses in its artificial turf and sells the
excess. It owns yarn production assets in the Netherlands, the
U.S., and Dubai. In addition, it owns facilities for producing
artificial turf in the U.K., Australia, New Zealand, and the U.S.
Here, it performs the tufting (attaching the yarn to the backing)
or weaving (where yarn and backing are woven into a turf carpet)
and coating stages of the production process. Synthetic turf is
then sold to installation intermediaries or direct to the
end-user.

By strategically developing into the more-downstream end of the
value chain, TenCate Grass has been able to capture a greater share
of market demand. The strategy also gives the company greater
control over the value chain, so that it can consistently deliver
high-quality synthetic yarn and grass to its customers. As such,
S&P forecasts the group will achieve an S&P Global Ratings-adjusted
EBITDA margin of 12.5%-13.5% over the next 12 months. In addition,
by taking this strategic direction, TenCate Grass has been able to
develop relationships with key decision makers, such as architects,
consultants, installers, and end-users. This provides it with key
insights into customer needs and local trends and so enables the
group to better align its research & development efforts with
market needs. The new products TenCate Grass develops are more
likely to see strong demand on launch.

Exposure to various end-markets and high customer diversification
provides some protection against downturns, in S&P's view. While
sporting applications represented 72% of 2020 revenue, landscaping
applications represented a healthy 28% and demand from these
end-markets have little correlation. In the landscaping market,
demand is fueled by urbanization and the shift to year-round green
lawns; in the sporting market, demand is fueled by the need to
improve player safety and the increased focus on exercise as part
of a healthy lifestyle.

TCG's vertical integration has enabled the group to achieve high
levels of diversification across customers. The company's
activities in the downstream segment accounted for about 35% of
2020 revenue, which enabled it to develop business relationships
with end-users such as municipalities, universities, and sport
associations. In the upstream and midstream parts of the value
chain, the company reaches customers through channels such as
installers, landscapers, and contractors. The high level of
customer diversification--no customer represents more than 3% of
revenue and the Top 3 customers represent only about 8.1% of 2020
revenue--provides some protection against potential customer loss,
in S&P's view.

The company's modest scale of operation and concentration on two
key regions--the U.S. and Europe--could limit revenue growth, in
our view. The TCG group generated revenue of EUR424.7 million and
S&P Global Ratings-adjusted EBITDA of EUR48 million in 2020 after
nonrecurring costs. At this operational scale, the company could be
more vulnerable to external changes like increased competition from
low-cost producers. These could offer synthetic yarn or synthetic
turf at competitive prices. In addition, the group generates most
of its revenue from the more-mature European and U.S. markets,
which together accounted for about 88% of 2020 revenue. It has
little exposure to emerging markets, which have higher growth
prospects, in our view. That said, the group has a good record of
maintaining its leading market position, despite the competition
from low-cost producers.

S&P attributes TCG's protection of its market position to its
ability to provide its customers with high-quality products within
a short timeframe. Its customers are less sensitive to prices, so
its efficient manufacturing footprint is key. Moreover, the TCG
group benefits from good knowledge of local specifications in its
relevant markets because its vertically integrated business model
gives it insights into market trends. It has, for example, been
able to focus on developing more-sustainable products to meet
potential new environmental regulations. The group is also exposed
to more dynamic markets in Australia, Asia-Pacific, and the Middle
East--together, these represent about 12% of revenue.

The group uses raw materials that are prone to price volatility,
which can make its profit margins more volatile in turn. The main
raw materials used to produce synthetic yarn include polypropylene
(PP) and polyethylene (PE). That said, it can pass price inflation
onto customers, after a delay. About 10% of its customers have
contracts that include indexed pricing on raw material, which
provides some protection against raw material price inflation. For
the remainder, TCG is more able to increase prices because its
customers focus on product quality and most producers of synthetic
yarn and synthetic turf are likely to increase their prices at the
same time. S&P estimates that price increases can be passed onto
customers after a delay of up to three months. TCG has a
diversified raw material base--PP and PE together represent about
20% of its total cost of goods sold. It has achieved this thanks to
the company's diversification in the downstream segment, which
requires other raw materials and other costs used in the
installation and maintenance of synthetic turf.

S&P's rating assessment is constrained by the company's ambition to
invest in both organic and acquisition growth opportunities. TCG is
primarily looking to acquire companies in the downstream part of
the value chain within the landscaping market, and to realize
cost-synergies on procurement, as the newly acquired company will
source its synthetic yarn from TenCate Grass. Market consolidation
in the downstream segment carries execution risks that could
pressure the group's credit metrics. For example, newly acquired
businesses could take longer to realize their full EBITDA
potential, cost synergies could take longer to materialize, and
integration costs could be larger than planned.

The company is managing its execution risks by taking a disciplined
approach, targeting small companies that have good local position,
and acquiring them at reasonable multiples. Moreover, the company
has a good track record of acquiring and successfully integrating
businesses, as demonstrated by the eight acquisitions it closed in
the 2017-2019 period, under the prior ownership. Together, these
represented EUR179 million of revenue. Over the same period, the
company's reported EBITDA margin increased to 10.4% from 8.6%,
which illustrates its successful integration and realization of
synergies. S&P said, "We also view the stability of the management
team that has led these acquisitions as a supportive factor.
Overall, we forecast the group will maintain its S&P Global
Ratings-adjusted debt-leverage ratio at 5.0x-5.5x in the next 12-18
months."

S&P said, "Our ratings and outlook are supported by the group's
sound cash flow conversion, which translates into a comfortable
free cash flow generation of about EUR30 million-EUR35 million in
the next 12-18 months. We forecast that the TCG group will invest
about EUR8 million-EUR12 million in capital expenditure (capex) a
year, including the necessary investments in maintenance, in
capacity expansion and considering capex required at acquired
companies. In our view, the low level of capex required is
supported by the well-invested asset base thanks to recent
investments made under the prior ownership, the long life of
equipment, and its capacity being sufficient to meet the growing
demand. We forecast that TCG's annual working capital requirement
will be about EUR4 million-EUR6 million, reflecting the integration
of inventories from acquired businesses and the need to build
inventories to meet the growing demand.

"The stable outlook indicates that, in our view, TCG is likely to
grow profitably, supported by the sales mix, as it increases its
share of the market for landscaping products in Europe. At the same
time, operational efficiencies support its margins.

"We expect the company to post adjusted EBITDA margins of
12.5%-13.5% in the next 12-18 months based on scale and channel
shift, with adjusted debt-to-EBITDA of 5.0x-5.5x and FOCF of EUR30
million-EUR35 million."

S&P could lower its rating in the next 12 months if:

-- Revenue growth and profitability are materially lower than
initial expectations, such that the leverage ratio deteriorates to
above S&P's expectation of about 5.0x-5.5x;

-- The company's liquidity deteriorates significantly; or

-- FOCF turns negative.

This could happen if competition in the EU landscaping markets is
greater than expected, and the company faces operational disruption
or fails to pass on raw materials price inflation on a timely
basis, which would weigh on the company cost base. Inability to
integrate a series of bolt-on acquisition could also depress
margin, translating into higher debt leverage.

S&P said, "We could also lower the rating if the company pursues a
more aggressive debt-financed acquisition strategy than we assume
in our base case, such as its debt-leverage ratio deteriorates
materially more than we expected and increases to, for example,
7.0x or above on a prolonged basis.

"We could raise the rating if TCG maintains a leverage ratio at the
stronger-end of the 4.0x-5.0x range on a sustained basis. This
could happen in case of faster expansion in the landscaping market
compared with our base case, combined with successful management of
raw material price volatility and seamless integration of recently
acquired companies."

Any rating upside would, however, depend on a firm commitment from
the new owner to maintain a less-leveraged capital structure over
the long term.




===============
P O R T U G A L
===============

ULISSES FINANCE 2: Moody's Ups EUR3.7MM E Notes Rating to (P)Ba3
----------------------------------------------------------------
Moody's investors Service has upgraded the following provisional
ratings of Ulisses Finance No. 2 to be issued by TAGUS-Sociedade de
Titularizacao de Creditos, S.A. ("the issuer"):

EUR203.7 million Class A Notes due Sep 2038, Upgraded to (P)Aa2
(sf); previously on Sep 13, 2021 Assigned (P)Aa3 (sf)

EUR10.0 million Class B Notes due Sep 2038, Upgraded to (P)Aa3
(sf); previously on Sep 13, 2021 Assigned (P)A2 (sf)

EUR20.0 million Class C Notes due Sep 2038, Upgraded to (P)Baa1
(sf); previously on Sep 13, 2021 Assigned (P)Baa2 (sf)

EUR11.3 million Class D Notes due Sep 2038, Upgraded to (P)Ba1
(sf); previously on Sep 13, 2021 Assigned (P)Ba2 (sf)

EUR3.7 million Class E Notes due Sep 2038, Upgraded to (P)Ba3
(sf); previously on Sep 13, 2021 Assigned (P)B1 (sf)

The transaction is a one year revolving cash securitisation of auto
loans originated by 321 Credito IFIC S.A ("321C", NR). 321C is a
Portuguese specialized lending company 100% owned by Banco CTT
(N.R.).

RATINGS RATIONALE

The rating action is prompted by the increase of Portugal
local-currency bond ceiling to Aa2 from Aa3.This follows Moody's
upgrade of the sovereign rating of Portugal from Baa3 to Baa2.

Class A notes are now capped at the higher local currency ceiling
of Aa2. The upgrade of all the notes reflect the modeling approach
for consumer loan asset-backed securities transactions that takes
into account the country's local currency country risk ceiling when
calibrating the portfolio loss distribution, which Moody's use to
generate portfolio losses.

Moody's has not changed the portfolio assumptions: lifetime
expected defaults of 5.5%, expected recoveries of 30.0% and
portfolio credit enhancement ("PCE") of 18.0%. The expected
defaults and recoveries capture Moody's expectations of performance
considering the current economic outlook, while the PCE captures
the loss Moody's expect the portfolio to suffer in the event of a
severe recession scenario. Expected defaults and PCE are parameters
used by Moody's to calibrate its lognormal portfolio loss
distribution curve and to associate a probability with each
potential future loss scenario in Moody's cash flow model to rate
Auto and Consumer ABS.

ESG - Environmental considerations:

The public and political debate about the future of combustion
engines and in particular diesel engines given the shift towards
alternative fuel vehicles such as electric cars is being reflected
in declining new diesel car registrations in several EMEA markets.
This transaction has high exposure to diesel engines with Euro 5
emission standards and below. Vehicles with older or larger engines
with elevated carbon dioxide emissions have a higher likelihood of
obsolescence and their recovery values are more sensitive to
changes in carbon emissions regulations and shifts in consumer
demand. Additional scenario analysis has been factored into Moody's
rating assumptions for these segments.

METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
September 2021.

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

Factors or circumstances that could lead to an upgrade of the
ratings of the notes would be (1) better than expected performance
of the underlying collateral; (2) significant improvement in the
credit quality of 321C; or (3) a lowering of Portuguese's sovereign
risk leading to the increase or removal of the local currency
ceiling cap.

Factors or circumstances that could lead to a downgrade of the
ratings would be (1) worse than expected performance of the
underlying collateral; (2) deterioration in the credit quality of
321C; or (3) an increase in Portuguese's sovereign risk.


VIRIATO FINANCE 1: Moody's Affirms (P)B2 Rating on Class E Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the provisional ratings of
Class A, B and C Notes and has affirmed the provisional ratings of
Classes D and E to be issued by Viriato Finance No. 1 ("the
issuer"):

EUR [ ] Class A Notes due Oct 2040, Upgraded to (P)Aa2 (sf);
previously on Sep 17, 2021 Assigned (P)Aa3 (sf)

EUR [ ] Class B Notes due Oct 2040, Upgraded to (P)A2 (sf);
previously on Sep 17, 2021 Assigned (P)A3 (sf)

EUR [ ] Class C Notes due Oct 2040, Upgraded to (P)Baa2 (sf);
previously on Sep 17, 2021 Assigned (P)Baa3 (sf)

EUR [ ] Class D Notes due Oct 2040, Affirmed (P)Ba2 (sf);
previously on Sep 17, 2021 Assigned (P)Ba2 (sf)

EUR [ ] Class E Notes due Oct 2040, Affirmed (P)B2 (sf);
previously on Sep 17, 2021 Assigned (P)B2 (sf)

Moody's has not assigned a rating to the Classes F Asset-Backed
Fixed Rate Notes, Class R Fixed Rate Notes and X Asset Backed Notes
due Oct 2040 amounting to EUR [ ] M.

The transaction is a one year revolving cash securitisation of
Portuguese unsecured consumer loans originated by WiZink Bank,
S.A.U. - Sucursal em Portugal (N.R.) (WiZink). The portfolio
consists of consumer loans used for undefined or general purposes.
WiZink will also acts as servicer in the transaction.

RATINGS RATIONALE

The rating action is prompted by the increase of Portugal
local-currency bond ceiling to Aa2 from Aa3. This follows Moody's
upgrade of the sovereign rating of Portugal from Baa3 to Baa2.

Class A notes are now capped at the higher local currency ceiling
of Aa2. The upgrade of the notes reflect the modeling approach for
consumer loan asset-backed securities transactions that takes into
account the country's local currency country risk ceiling when
calibrating the portfolio loss distribution, which Moody's use to
generate portfolio losses.

Moody's has not changed the portfolio assumptions: lifetime
expected defaults of 8.5%, expected recoveries of 15.0% and
portfolio credit enhancement ("PCE") of 24.0%. The expected
defaults and recoveries capture Moody's expectations of performance
considering the current economic outlook, while the PCE captures
the loss Moody's expect the portfolio to suffer in the event of a
severe recession scenario. Expected defaults and PCE are parameters
used by Moody's to calibrate its lognormal portfolio loss
distribution curve and to associate a probability with each
potential future loss scenario in Moody's cash flow model to rate
Auto and Consumer ABS.

The principal methodology used in these ratings was "Moody's
Approach to Rating Consumer Loan-Backed ABS" published in September
2021.

FACTORS THAT WOULD LEAD AN UPGRADE OR DOWNGRADE OF THE RATINGS:

Factors or circumstances that could lead to an upgrade of the
ratings of the Notes would be (1) better than expected performance
of the underlying collateral; or (2) a lowering of Portuguese's
sovereign risk leading to an higher local currency ceiling cap.

Factors or circumstances that could lead to a downgrade of the
ratings would be (1) worse than expected performance of the
underlying collateral; (2) deterioration in the credit quality of
WiZink; or (3) an increase in Portuguese's sovereign risk.




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

CREDIT BANK: Fitch Gives  Final 'BB' on USD500MM Unsec. Eurobond
----------------------------------------------------------------
Fitch Ratings has assigned Credit Bank of Moscow's (CBM) USD500
million 3.875% five-year senior unsecured Eurobond issue a final
long-term rating of 'BB'.

The bonds are issued by CBM's SPV, CBOM Finance PLC (Ireland),
which on-lends the proceeds to the bank.

The assignment of the final rating follows the completion of the
issue and receipt of documents conforming to the information
previously received. The final rating is the same as the expected
rating assigned on 9 September 2021 (see Fitch Rates Credit Bank of
Moscow's Upcoming Eurobond 'BB(EXP)' at www.fitchratings.com).

KEY RATING DRIVERS

The Eurobond's rating is in line with CBM's Long-Term Issuer
Default Rating (IDR) of 'BB', as the notes represent unconditional,
senior unsecured obligations of the bank.

CBM's 'BB' IDRs are driven by the bank's standalone strength, as
reflected in its 'bb' Viability Rating (VR). CBM's VR factors in
its large franchise, manageable volume of high-risk assets relative
to its moderate pre-impairment profit and core capital, and its
concentrated funding, which is balanced by healthy liquidity.

RATING SENSITIVITIES

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

-- The senior debt rating could be upgraded if the IDRs were
    upgraded.

-- An upgrade of the IDRs would require a strengthening of the
    bank's franchise and business model, including a reduction in
    balance-sheet and revenue concentrations. A marked improvement
    in asset quality, higher core capital ratios and reduced risks
    stemming from double leverage at the holdco level would also
    be credit positive.

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

-- The senior debt rating could be downgraded if the IDRs were
    downgraded.

-- CBM's IDRs would be downgraded if there was a material asset
    quality deterioration resulting in core capital erosion. For
    example, Fitch may take this view if annualised loan
    impairment charges exceed 3.5% of average gross loans in two
    to three consecutive semi-annual reporting periods, which
    could translate into negative or close to negative operating
    performance, or if Fitch's assessment of the bank's net high-
    risk assets rises significantly above 0.5x common equity Tier
    1 capital.

BEST/WORST CASE RATING SCENARIO

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




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

BULB: Seeks Bailout to Stay Afloat Amid Surging Gas Prices
----------------------------------------------------------
Michael Race at BBC News reports that the UK's sixth largest energy
company, Bulb, is seeking a bailout to stay afloat amid surging
wholesale gas prices.

According to BBC, the company, with 1.7 million customers, is
working with the investment bank Lazard to try to shore up its
balance sheet.

It is the latest energy company battling to avoid going bust, with
at least four smaller UK firms expected to go out of business next
week, BBC notes.

High global demand for gas has caused a recent surge in wholesale
prices, BBC states.

A bailout for Bulb could come as part of a joint venture or merger
with another company, with a further option being a cash injection
from investors, BBC relays, citing the Financial Times, who first
reported the story.

In a statement, Bulb told BBC: "From time to time, we explore
various opportunities to fund our business plans and further our
mission to lower bills and lower CO2.

"Like everyone in the industry, we're monitoring wholesale prices
and their impact on our business."

Industry group Oil & Gas UK said wholesale prices for gas had
increased by 250% since January -- with a 70% rise since August,
according to BBC.

The price hike has left some companies unable to provide their
customers with the energy they have paid for, BBC says.

However, if a supplier fails, energy regulator Ofgem will ensure
supplies continue for affected households, and they will not lose
money owed to them, BBC discloses.

According to BBC, a new energy supplier would be responsible for
taking on any credit balances a customer may have.


CHESHIRE PLC 2021-1: S&P Assigns B Rating on Class F Notes
----------------------------------------------------------
S&P Global Ratings assigned credit ratings to Cheshire 2021-1 PLC's
class A to F-Dfrd U.K. RMBS notes. At closing, the issuer also
issued unrated class Z and VRR notes, and S1 and S2 certificates.

Cheshire 2021-1 is a static RMBS transaction that securitizes a
portfolio of GBP211.6 million owner-occupied and BTL mortgage loans
secured on properties in the U.K.

The transaction is a refinancing of the Dukinfield II PLC
transaction, which closed in September 2016.

At closing, the issuer used the issuance proceeds to purchase the
full beneficial interest in the mortgage loans from the seller
(Cheshire Seller 2021-1 Ltd.). The issuer granted security over all
its assets in the security trustee's favor.

S&P considers the collateral to be nonconforming based on the
prevalence of loans to self-certified borrowers and borrowers with
adverse credit history, such as prior county court judgments, an
individual voluntary arrangement, or a bankruptcy order.

The pool is well-seasoned with 100% of loans being more than 10
years seasoned.

Of the pool, 30.1% of the mortgage loans by current balance have
had a historical payment holiday due to the COVID-19 pandemic.

Approximately 7.7% of the pool comprises BTL loans, and the
remaining 92.3% are owner-occupier loans.

There is high exposure to interest-only loans in the pool at 92.7%,
and 15.6% of the mortgage loans are currently in arrears greater
than (or equal to) one month.

A liquidity reserve fund provides liquidity support for the class A
and B-Dfrd notes (subject to conditions for the B-Dfrd notes), and
principal can be used to pay senior fees and interest on the notes
subject to various conditions.

Pepper (UK) Ltd. is the servicer in this transaction.

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

S&P said, "Our credit and cash flow analysis and related
assumptions consider the transaction's ability to withstand the
potential repercussions of the COVID-19 outbreak, namely, higher
defaults and longer recovery timing. Considering these factors, we
believe that the available credit enhancement is commensurate with
the ratings assigned."

  Ratings

  CLASS     RATING*     CLASS SIZE (GBP)
  A         AAA (sf)     156,776,000
  B-Dfrd    AA (sf)       13,064,000
  C-Dfrd    A (sf)        11,054,000
  D-Dfrd    BBB (sf)       6,029,000
  E-Dfrd    BB (sf)        5,024,000
  F-Dfrd    B (sf)         3,014,000
  Z         NR             6,035,000
  S1 certs  NR                   N/A
  S2 certs  NR                   N/A
  Y certs   NR                   N/A
  VRR loan notes  NR      10,603,000

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


DOWSON PLC 2019-1: S&P Affirms 'BB+' Rating on Class D Notes
------------------------------------------------------------
S&P Global Ratings raised its credit ratings on Dowson 2019-1 PLC's
class A notes to 'AAA (sf)' from 'AA (sf)', class B notes to 'AA-
(sf)' from 'A- (sf)', and class C notes to 'A- (sf)' from 'BBB
(sf)'. At the same time, S&P has affirmed its 'BB+ (sf)' rating on
the class D notes.

S&P said, "The ratings actions follow our review of the
transaction's performance and the application of our current
criteria, and reflect our assessment of the payment structure
according to the transaction documents.

"Under our operational risk analysis, given the servicer's, Oodle
Financial Services Ltd., slightly longer operating history (four
years of complete performance data) as compared with when we
assessed it at closing, we now consider disruption risk to be
moderate. This assessment, along with a presence of a cold back up
servicer, leads to maximum potential ratings on the notes at 'AAA'
under our operational risk criteria."

The transaction has been amortizing strictly sequentially since
closing in September 2019. This has resulted in increased credit
enhancement for the outstanding notes, most notably for the senior
and mezzanine notes. As of the June 2021 servicer report, the pool
factor had declined to 42.1% (for non-defaulted receivables), and
the available credit enhancement for the class A, B, C, and D notes
has increased to 84.24%, 33.26%, 22.58%, and 13.12%, respectively,
compared with 36.75%, 15.27%, 10.77%, and 6.78% at closing. The
uncollateralized class X1-Dfrd notes have now redeemed.

S&P said, "Following our review, we have maintained our base-case
hostile termination assumption at 14.0% and our base-case voluntary
termination assumption at 3.75%, which are both in line with at
closing.

"Our hostile terminations multiples and voluntary termination
multiples remain unchanged and in line with our assumptions at
closing.

"We have also maintained the same recovery assumptions as at
closing. Lastly, as the collateral backing the notes comprises U.K.
fully amortizing fixed-rate auto loan receivables arising under
hire purchase agreements, the transaction is not exposed to
residual value risk."

  Table 1

  Credit Assumptions

  PARAMETER                                 CURRENT

  Gross loss base case (%)                     14.0
  Gross loss multiple ('AAA')                 4.25x
  Voluntary terminations base case (%)          2.5
  Voluntary terminations multiple ('AAA')        3x
  Stressed recovery rate ('AAA') (%)           27.5

S&P said, "We have performed our cash flow analysis to test the
effect of the amended credit assumptions and deleveraging in the
structure.

"Our cash flow analysis indicates that the available credit
enhancement for the class A, B, and C notes is sufficient to
withstand the credit and cash flow stresses that we apply at the
'AAA (sf)', 'AA- (sf)', and 'A- (sf)' ratings, respectively. We
have therefore raised to 'AAA (sf)', 'AA- (sf)', and 'A- (sf)',
from 'AA (sf)', 'A- (sf)', and 'BBB (sf)' our ratings on the class
A, B, and C notes, respectively.

"Our cash flow analysis indicates that the available credit
enhancement for the class D notes is sufficient to withstand the
credit and cash flow stresses that we apply at the 'BB+ (sf)'
rating. We have therefore affirmed our 'BB+ (sf)' rating on the
class D notes.

"Our credit stability analysis indicates that the maximum projected
deterioration that we would expect at each rating level for
one-year horizons under moderate stress conditions is in line with
our criteria.

"There are no rating constraints under our operational risk
criteria. In addition, there are no rating constraints under our
counterparty or structured finance sovereign risk criteria, and
legal risks continue to be adequately mitigated, in our view."

Dowson 2019-1 is an asset-backed securitization backed by a
portfolio of U.K. auto loans receivables originated by Oodle
Financial Services Ltd.


FUTURE RENEWABLES: Enters Administration, Turbines Up for Sale
--------------------------------------------------------------
Business Sale reports that a portfolio of 10 wind turbines across
Scotland, England and Northern Ireland are to be marketed for sale
by administrators following the collapse of the company that owned
them.

Edinburgh-headquartered Future Renewables Eco (FRE) entered
administration earlier this week, appointing Interpath Advisory to
handle the process, Business Sale relates.

FRE was established in 2015, with funding coming largely from GBP24
million that was invested by 750 bondholders between 2015 and 2017.
The company employed no full-time staff, with maintenance carried
out by contractors, Business Sale notes.

The firm's 10 turbines are located across nine fully operational
sites, with each generating profit after operational costs,
Business Sale discloses.  However, the profits generated proved
insufficient to meet bondholders' interest payments with the
company also having overdue capital repayments, Business Sale
states.

According to Business Sale, in an effort to address these cashflow
issues, FRE sought to change bondholders' debt terms.  A bondholder
meeting to vote on this is scheduled for Sept. 28, however,
following a high volume of proxy votes against the proposal, the
group's directors have moved to put the firm into administration,
Business Sale relays.

Administrators from Interpath will now continue to operate FRE's
wind turbines while looking to secure a sale of the portfolio,
according to Business Sale.

"The UK is renowned for its expertise in renewable energy, and
whilst FRE has been successful in compiling a portfolio of
operationally successful assets, there was a mis-match between
levels of cash being generated and the capital structure of the
business," Business Sale quotes Interpath Advisory's Chief
Executive Blair Nimmo as saying.

"Understandably, bondholders will be anxious about the impact of
the administration appointments upon the sums which FRE owe them
and will have many questions.  Over the coming days we will be
contacting all bondholders to explain the implications of the
administration appointments and to confirm next steps," Interpath's
Managing Director in Scotland, Alistair McAlinden, as cited by
Business Sale, said.


NORTHERN PROVIDENT: Enters Creditors' Voluntary Liquidation
-----------------------------------------------------------
Kathryn Gaw at Peer2Peer Finance News reports that Innovative
Finance ISA (IFISA) manager Northern Provident Investments has gone
into liquidation, leaving its 20 IFISA-eligible bonds in limbo.

The Belfast-based investment company officially entered creditors'
voluntary liquidation on August 20, 2021, Peer2Peer Finance News
relates.

It was first authorized by the Financial Conduct Authority (FCA) in
July 2015, and went on to gain approval from HMRC to act as an
IFISA manager, Peer2Peer Finance News recounts.

According to newly-released correspondence by the FCA, in February
2020, the regulator told Northern Provident Investments that it
must cease approving financial promotions for issuers of
mini-bonds, Peer2Peer Finance News discloses.  This followed the
FCA's temporary ban on the marketing of mini-bonds, which came into
force on January 1, 2020, Peer2Peer Finance News notes.

Soon after, Northern Provident placed a message on its website
telling users that it was no longer offering mini-bonds, Peer2Peer
Finance News states.

According to Peer2Peer Finance News, in August 2021, a message
replaced the website, stating that "Northern Provident is ceasing
to trade and will no longer perform any operations on behalf of its
customers."

At the point of liquidation, Northern Provident Investments acted
as IFISA manager of 20 bonds, Peer2Peer Finance News states.  These
included a litigation finance IFISA (Just ISA), a care home
investment fund (Barbican ISA), and the Azurite ISA -- an
IFISA-eligible bond which funds property renovations in Monaco,
Peer2Peer Finance News discloses.

Northern Provident also acted as ISA manager on mini-bond provider
Blackmore Bonds, which entered into administration in April 2020
amid claims that investors had not received repayments, Peer2Peer
Finance News relates.

Other bonds under Northern Provident's care included the Absolute
ISA, the Acorn ISA Bond, the Choices ISA, Convivia Capital's
Convivia ISA, Fluid ISA, FREE Wind ISA, Knightsbridge Capital Bond,
the Northbridge ISA, the property-backed Ziphouse IFISA, Access
Commercial bonds, Astute Capital's IFISA, and Satchi Holdings'
ISA-eligible bond, according to Peer2Peer Finance News.

It also managed IFISA-eligible bonds on behalf of the
Haletone/Shetland Space Centre, Synthesis Analytics UK, Summit
Resorts & Development Ltd, The Electric Vehicle Company, and Leonne
International, Peer2Peer Finance News states.

The FCA has warned consumers to be wary of scammers in the wake of
the company's liquidation, Peer2Peer Finance News relates.

The Financial Services Compensation Scheme (FSCS) is in the early
stages of investigating whether there are any claims against
Northern Provident Investment that meet the qualifying conditions
for compensation, Peer2Peer Finance News discloses.

Jason Baker and Geoff Rowley of FRP Advisory Trading Limited have
been appointed as liquidators, Peer2Peer Finance News recounts.


PTS ACADEMY: Enters Liquidation Following Financial Woes
--------------------------------------------------------
Matthew Harris at Northants Live reports that PTS Academy, the
former sponsor of Northampton Town FC's Sixfields Stadium, has gone
bust.

Sixfields was renamed "The PTS Academy Stadium" in 2018 after the
company bought the naming rights for five years, Northants Live
recounts.

But the deal fell through this summer after the company had cited
financial troubles, causing the home of the Cobblers to revert to
its original name two years early, Northants Live discloses.

PTS, or Personal Track Safety, fell into arrears of GBP4,000,000,
Northants Live relays, citing documents available on the government
website.

According to Northants Live, the public documents show:

   -- GBP1,500,000 owed to Lloyds Bank
   -- GBP429,129.25 owed in business loans
   -- GBP155,059.94 owed to HMRC
   -- GBP70,197.30 owed to Northampton Town FC
   -- GBP60,000 owed to Northampton Saints
   -- GBP23,274.14 owed in rent

PBC Business Recovery is overseeing PTS' liquidation, Northants
Live notes.


[*] UK: Energy Companies Collapse Due to Surging Gas Prices
-----------------------------------------------------------
Liv McMahon at The Scotsman reports that the UK Government said on
Sept. 20 that it had been holding roundtable discussions with
senior representatives of larger energy suppliers as gas prices
continue to rise to new highs.

Wholesale gas prices have climbed by 250% since the start of 2021
and saw a 70% spike in August alone, The Scotsman discloses.

According to The Scotsman, Business Secretary Kwasi Kwarteng said
that he would be meeting with smaller suppliers, disproportionately
affected by rising costs, as well as the UK's "big six" energy
suppliers -- British Gas, EDF Energy, EON, Npower, Scottish Power
and SSE.

The energy price cap is set to remain in place but rise by roughly
GBP139 a year to GBP1,277 for a typical gas and electricity
customer from October 1, The Scotsman states.

The increase comes as the UK Government's Universal Credit GBP20
uplift will end in October, The Scotsman notes.

The increased costs of wholesale gas in the UK have imposed tough
trading conditions for many energy suppliers and gas companies who
now find themselves paying higher costs for gas than they are
receiving from customers, The Scotsman relates.

Currently, customers of smaller energy suppliers will be paying
less for their gas than their suppliers are, leaving little room to
meet the costs of trading and profit, The Scotsman discloses.

As a result, five companies have already been forced to close their
doors due to rising gas costs, The Scotsman relays.

According to The Scotsman, the companies which have already gone
into administration due to the climbing costs of wholesale gas
prices are:

- Utility Point (September 14)

- People's Energy (September 14)

- PFP Energy (September 7)

- MoneyPlus Energy (September 7)

- HUB Energy (August 9)

The fall of Midlothian gas company, People's Energy, has seen the
firm's almost 500 jobs in the region put at risk, The Scotsman
states.



                           *********


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 2021.  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 * * *