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       T R O U B L E D   C O M P A N Y   R E P O R T E R

                          E U R O P E

          Wednesday, October 2, 2024, Vol. 25, No. 198

                           Headlines



B E L G I U M

APOLLO FINCO: EUR348MM Bank Debt Trades at 16% Discount


F R A N C E

ALTICE FRANCE: EUR1.72BB Bank Debt Trades at 24% Discount
CASSINI SAS: EUR141MM Bank Debt Trades at 16% Discount


G E R M A N Y

ADAPA GMBH: EUR475MM Bank Debt Trades at 63% Discount
OQ CHEMICALS: S&P Raises ICR to 'CCC-', Outlook Developing


I R E L A N D

CAIRN CLO XVIII: Fitch Assigns 'B-sf' Rating on Class F Notes
PENTA CLO 14: Fitch Assigns 'B-sf' Final Rating on Class F-R Notes


P O R T U G A L

CONSUMER TOTTA 2: Fitch Assigns 'BBsf' Final Rating on Cl. D Notes


T U R K E Y

TURKIYE WEALTH: Fitch Hikes LongTerm IDRs to 'BB-', Outlook Stable
[*] Fitch Hikes IDRs on 8 Turkish Local/Regional Governments to BB-


U N I T E D   K I N G D O M

AMPHORA FINANCE: GBP301MM Bank Debt Trades at 58% Discount
BALLIE EDINBURGH: Quantuma Advisory Named as Joint Administrators
CIEP EPOCH: GBP176MM Bank Debt Trades at 44% Discount
CONSTELLATION AUTOMOTIVE: GBP325MM Bank Debt Trades at 28% Discount
CROWN AGENTS: Fitch Affirms 'BB' LongTerm IDR, Outlook Stable

EUROSAIL 2006-1: S&P Lowers Class D1a Notes Rating to 'B(sf)'
EUROSAIL 2006-3NC: S&P Cuts Rating on D1a & D1c Notes to 'B(sf)'
EUROSAIL-UK 2007-3BL: S&P Lowers Cl. E1c Notes Rating to 'CCC(sf)'
EXTRASPACE SOLUTIONS: Ernst & Young Named as Joint Administrators
PHION THERAPEUTICS: KPMG Named as Joint Administrators

SQUARE ROOT: CG&Co Named as Joint Administrators
WHITE HART: Opus Restructuring Named as Administrators

                           - - - - -


=============
B E L G I U M
=============

APOLLO FINCO: EUR348MM Bank Debt Trades at 16% Discount
-------------------------------------------------------
Participations in a syndicated loan under which Apollo Finco BV is
a borrower were trading in the secondary market around 83.8
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The EUR348 million Term loan facility is scheduled to mature on
October 8, 2028.

Apollo Finco BV was established in June 2021. It is a unit of
Apollo Bidco. The Company's country of domicile is Belgium.



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

ALTICE FRANCE: EUR1.72BB Bank Debt Trades at 24% Discount
---------------------------------------------------------
Participations in a syndicated loan under which Altice France SA is
a borrower were trading in the secondary market around 75.8
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The EUR1.72 billion Term loan facility is scheduled to mature on
August 31, 2028. About EUR1.70 billion of the loan is withdrawn and
outstanding.

Altice France provides wireless telecommunication services. The
Company offers fiber optic network solutions for all type of media.
Altice France serves customers in France.

CASSINI SAS: EUR141MM Bank Debt Trades at 16% Discount
------------------------------------------------------
Participations in a syndicated loan under which Cassini SAS is a
borrower were trading in the secondary market around 84.5
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The EUR141 million Term loan facility is scheduled to mature on
March 28, 2026. The amount is fully drawn and outstanding.

Cassini SAS operates as a holding company to acquire the entire
equity capital from current parent Comete Holding SAS. The
Company's country of domicile is France.



=============
G E R M A N Y
=============

ADAPA GMBH: EUR475MM Bank Debt Trades at 63% Discount
-----------------------------------------------------
Participations in a syndicated loan under which adapa GmbH is a
borrower were trading in the secondary market around 36.8
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The EUR475 million Term loan facility is scheduled to mature on
September 24, 2028. The amount is fully drawn and outstanding.

Adapa GmbH provides packaging products. The Company offers shrink
films, laminates, wicket bags, tobacco pouches, and bread bags. The
Company's country of domicile is Germany.

OQ CHEMICALS: S&P Raises ICR to 'CCC-', Outlook Developing
----------------------------------------------------------
S&P Global Ratings raised its rating on OQ Chemicals International
Holding GmbH (OQ Chemicals) to 'CCC-' from 'D', and its issue
rating on the group's senior secured debt to 'CCC-' from 'D'.

S&P said, "We also assigned our 'CCC+' issue rating to the super
senior bridge loans of EUR37.04 million and $45.19 million. The
issue rating is in line with the preliminary rating we assigned on
July 23, 2024.

"The developing outlook reflects that we could raise or lower our
ratings depending on the execution of the sale of OQ Chemicals, and
on the company's ability to address its liquidity requirements."

OQ Chemicals completed its amend-and-extend transaction on its
debt. Lenders have consensually voted for the transaction, which
pushed the debt maturities to Dec. 31, 2026 from October 2024. The
term loan B-1 and B-2 have been upsized with the capitalized
interests from April and July 2024, as well as the ticking fees and
other fees. The revolving credit facility (RCF) has been downsized
to EUR33.4 plus accrued fees and interests. The capital structure
now mainly comprises:

-- EUR555 million term loan B-1;
-- $478 million term loan B-2;
-- EUR75 million super senior bridge funding; and
-- EUR33 million RCF.

The maturity of the EUR330 million shareholder loan hold by Majan
Energy B.V. was also extended to 2027.

S&P said, "Our rating remains constrained by uncertainty
surrounding the future owner and capital structure of OQ Chemicals,
which could ultimately result in a debt restructuring or
debt-to-equity swap in the absence of no adequate offer. In
parallel with the amend and extend, OQ Chemicals is conducting a
merger and acquisition (M&A) process to achieve a bid that would
allow for a full par recovery plus accrued interests and all
applicable fees for the lenders. We believe that if OQ Chemicals
does not receive an appropriate offer, lenders could eventually
take control of the company, with an associated debt restructuring
or debt-to-equity swap, which would be tantamount to a default
according to our methodology. On the flip side, an adequate offer
could lead to a clearer ownership structure and more sustainable
capital structure, leading to upside rating pressure. We will
monitor any progress of the M&A process in the coming months.

"Liquidity has improved with the maturity extension, but remains
less than adequate with tight covenant headroom, in our view. At
the beginning of September, OQ Chemicals had about EUR63 million of
cash considered as accessible. However, our liquidity assessment is
constrained by some trapped cash, and the RCF being fully drawn,
leaving little liquidity flexibility. We also foresee limited
covenant headroom and believe that OQ Chemicals may breach its
covenant under the asset-backed security program if it does not
obtain a covenant waiver--see covenant section below.

"In 2024, we expect deeply negative free operating flows, mainly
due to the decrease in trade payables as suppliers have tightened
their payment terms following the refinancing issues and
downgrades. OQ Chemicals' working capital position could revert
next year, with strongly positive free operating cash flows. We
expect capital expenditure (capex) to reduce materially to about
EUR60 million in 2024 from EUR136 million in 2023, as the company
has completed its project Propel (integrated supply of
propionaldehyde, utilities, and sites services to Röhm at the Bay
City site).

"OQ Chemicals' performance has likely bottomed out in 2023 and we
expect a sequential recovery in 2024-2025, although our metrics are
constrained by extraordinary items and the incident at its German
site this year.In the first six months of 2024, volumes contracted
by 6% and sales fell by 14%. However, the start of the year was
marked by operational issues caused by an external supplier related
to one of the synthesis gas units at its Oberhausen site. Absent
this incident, growth would have been positive. We also note that
OQ Chemicals posted revenue and EBITDA above 2023 levels for both
oxo intermediate and oxo derivatives in the months of June, July,
and August. Furthermore, we expect results for the second half of
this year to benefit from a favorable basis for comparison, as the
second half of 2023 was impaired by longer-than-expected turnaround
and particularly weak results in the fourth quarters. We continue
to acknowledge the difficult operational environment for chemicals
in Europe, especially in Germany, associated with high energy costs
and intense competitive pressure from exports. Overall, we expect
sales to contract by about 3%-6% in 2024, before rebounding to over
10% in 2025. We also assumed an adjusted EBITDA margin of 10%-11%
in 2024, and 12%-13% in 2025. Our adjusted EBITDA includes
consulting and refinancing fees of over EUR50 million in 2024.

"We expect adjusted leverage to remain high in 2024 and reduce in
2025. We forecast adjusted debt to EBITDA of 11.5x-12.5x in 2024,
from 14.4x in 2023. We note that the debt amount has increased due
to the capitalized interests and fees, and the issuance of the
EUR75 million super senior debt. We expect it will improve to
8.5x-9.5x in 2025, mainly on the back of gradual demand recovery
and improved profitability, as well as lower consulting fees.
However, we make significant adjustments to our metrics. Our debt
figures include about EUR85 million of trade receivables sold,
about EUR30 million of lease liabilities, and about EUR55 million
of pension liabilities. We also include the EUR330 million
shareholder loan provided by Majan Energy. We do not net the cash
in our metrics.

"The developing outlook reflects that we could raise or lower our
ratings depending on the execution of the sale of OQ Chemicals, and
on the company's ability to address its liquidity requirements."

S&P could lower the ratings on OQ Chemicals if:

-- The company failed to secure a par (plus accrued) cash recovery
for the lenders offer from an external buyer, which could
ultimately result in a debt restructuring or a debt-to-equity swap;
or

-- The company failed to maintain sufficient liquidity and meet
its financial covenants, such that it would result in a default.

S&P could raise the ratings on OQ Chemicals if:

-- The company received an adequate (that is, par plus accrued
cash recovery) offer, leading to a much lower risk of a distressed
exchange or debt restructuring;

-- Liquidity is adequate and the company meets its financial
obligations; and

-- Its operating performance and adjusted leverage gradually
improve, for example supported by higher demand and a controlled
cost base.




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

CAIRN CLO XVIII: Fitch Assigns 'B-sf' Rating on Class F Notes
-------------------------------------------------------------
Fitch Ratings has assigned Cairn CLO XVIII DAC final ratings.

   Entity/Debt                  Rating             Prior
   -----------                  ------             -----
Cairn CLO XVIII DAC

   Class A XS2872283929     LT AAAsf  New Rating   AAA(EXP)sf
   Class B XS2872284141     LT AAsf   New Rating   AA(EXP)sf
   Class C XS2872284497     LT Asf    New Rating   A(EXP)sf
   Class D XS2872284653     LT BBB-sf New Rating   BBB-(EXP)sf
   Class E XS2872284810     LT BB-sf  New Rating   BB-(EXP)sf
   Class F XS2872285031     LT B-sf   New Rating   B-(EXP)sf
   Class Z XS2872285205     LT NRsf   New Rating   NR(EXP)sf
   Sub Notes XS2872285460   LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

Cairn CLO XVIII DAC is a securitisation of mainly senior secured
loans (at least 90%) with a component of senior unsecured,
mezzanine, and second-lien loans. Note proceeds have been used to
fund a portfolio with a target par of EUR400 million. The portfolio
is actively managed by Cairn Loan Investments II LLP. The
collateralised loan obligation (CLO) has a 4.6-year reinvestment
period and a 7.5-year weighted average life (WAL) test.

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors to be in the 'B' category. The
Fitch weighted average rating factor (WARF) of the identified
portfolio is 23.8.

High Recovery Expectations (Positive): At least 90% of the
portfolio comprises 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 63.6%.

WAL Step-Up Feature (Neutral): The transaction can extend the WAL
by one year at the step-up date one year after closing. The WAL
extension is subject to conditions including fulfilling the
portfolio-profile, collateral-quality, coverage tests and the
adjusted collateral principal amount being at or above the
reinvestment target par, with defaulted assets at their collateral
value on the step-up date.

Diversified Portfolio (Positive): The transaction includes various
concentration limits, including a maximum exposure to the three
largest Fitch-defined industries in the portfolio at 40%. These
covenants ensure that the asset portfolio will not be exposed to
excessive concentration.

Portfolio Management (Neutral): The transaction has four matrices;
two effective at closing with fixed-rate limits of 5% and 10%, and
two one year after closing (or two years after closing if the WAL
is extended) with fixed-rate limits of 5% and 10%, provided that
the portfolio balance (defaults at Fitch-calculated collateral
value) is above target par. All four matrices are based on a top-10
obligor concentration limit of 20%.

The closing matrices correspond to a 7.5-year WAL test while the
forward matrices correspond to a 6.5-year WAL test. The transaction
has an approximately 4.6-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 (Positive): The WAL used for the transaction's
matrix and the Fitch-stressed portfolio analysis is 12 months less
than the WAL covenant. This is to account for the strict
reinvestment conditions envisaged by the transaction after its
reinvestment period. These include, among others, passing both the
coverage tests and the Fitch 'CCC' bucket limitation test post
reinvestment as well a WAL covenant that progressively steps down
over time, both before and after the end of the reinvestment
period. Fitch believes these conditions would reduce the effective
risk horizon of the portfolio during stress periods.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A 25% increase of the mean default rate (RDR) across all ratings
and a 25% decrease of the recovery rate (RRR) across all ratings of
the identified portfolio would have no impact on the class A, B, C
and E notes, would lead to downgrade of no more than one notch for
the class D notes and ]to below 'B-sf' for the class F notes.

Downgrades based on the identified portfolio may occur if the loss
expectation is larger than initially assumed, due to unexpectedly
high levels of defaults and portfolio deterioration. Due to the
better metrics and shorter life of the identified portfolio than
Fitch-stressed portfolio, the class B to F notes have a cushion of
two notches.

Should the cushion between the identified portfolio and the
Fitch-stressed portfolio be eroded either due to manager trading or
negative portfolio credit migration, a 25% increase of the mean RDR
and a 25% decrease of the RRR across all ratings of the
Fitch-stressed portfolio would lead to downgrades of up to three
notches for the rated notes.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

A 25% reduction of the mean RDR across all ratings and a 25%
increase in the RRR across all ratings of the Fitch-stressed
portfolio would lead to upgrades of up to three notches for the
rated notes, except for the 'AAAsf' rated notes.

During the reinvestment period, upgrades, which are based on the
Fitch-stressed portfolio, may occur on better-than-expected
portfolio credit quality and a shorter remaining WAL test, allowing
the notes to withstand larger-than-expected losses for the
remaining life of the transaction. After the end of the
reinvestment period, upgrades, except for the 'AAAsf' notes, may
result from stable portfolio credit quality and deleveraging,
leading to higher credit enhancement and excess spread available to
cover losses in the remaining portfolio.

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.

ESG Considerations

Fitch does not provide ESG relevance scores for Cairn CLO XVIII
DAC.

In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


PENTA CLO 14: Fitch Assigns 'B-sf' Final Rating on Class F-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned Penta CLO 14 DAC reset notes final
ratings.

   Entity/Debt                Rating               Prior
   -----------                ------               -----
Penta CLO 14 DAC

   A-1-R XS2876585915     LT AAAsf  New Rating     AAA(EXP)sf
   A-2-R XS2876586137     LT AAAsf  New Rating     AAA(EXP)sf
   A-Loan                 LT PIFsf  Paid In Full   AAAsf
   A-Notes XS2580301336   LT PIFsf  Paid In Full   AAAsf
   B XS2580301500         LT PIFsf  Paid In Full   AAsf
   B-R XS2876586301       LT AAsf   New Rating     AA(EXP)sf
   C XS2580301765         LT PIFsf  Paid In Full   Asf
   C-R XS2876586723       LT Asf    New Rating     A(EXP)sf
   D XS2580301922         LT PIFsf  Paid In Full   BBB-sf
   D-R XS2876587028       LT BBB-sf New Rating     BBB-(EXP)sf
   E XS2580302144         LT PIFsf  Paid In Full   BB-sf
   E-R XS2876587374       LT BB-sf  New Rating     BB-(EXP)sf
   F XS2580302490         LT PIFsf  Paid In Full   B-sf
   F-R XS2876587531       LT B-sf   New Rating     B-(EXP)sf
   X-R XS2876585758       LT AAAsf  New Rating     AAA(EXP)sf

Transaction Summary

Penta CLO 14 DAC is a securitisation of mainly senior secured
obligations (at least 90%) with a component of senior unsecured,
mezzanine, second-lien loans and high-yield bonds. Note proceeds
have been used to refinance the original rated notes and to fund a
portfolio with a target par of EUR400 million.

The portfolio is actively managed by Partners Group. The
collateralised loan obligation (CLO) has a reinvestment period of
about 4.6 years and an 8.5 year weighted average life (WAL) test
limit.

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch places the
average credit quality of obligors in the current portfolio at
'B'/'B-'. The Fitch weighted average rating factor (WARF) of the
current portfolio is 25.3.

High Recovery Expectations (Positive): At least 90% of the
portfolio comprises 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 current portfolio is 61.1%.

Diversified Asset Portfolio (Positive): The transaction includes
various concentration limits in the portfolio, including a maximum
exposure to the three largest Fitch-defined industries at 40%.
These covenants ensure the asset portfolio will not be exposed to
excessive concentration.

Portfolio Management (Neutral): The transaction has an
approximately 4.6-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.

The transaction also includes four Fitch test matrices, of which
two are effective at closing. The closing matrices correspond to a
top-10 obligor limit at 20%, and fixed-rate obligation limits of 5%
and 10% and an 8.5-year WAL covenant. It has two forward matrices
corresponding to the same top-10 obligor limit and fixed-rate asset
limits, and a 7.5-year WAL covenant, which the manager can switch
to one year after closing, provided that the collateral principal
amount (defaults at Fitch-calculated collateral value) is at least
at the reinvestment target par balance, and subject to Fitch
confirmation.

Cash Flow Modelling (Neutral): The WAL used for the stressed-cased
portfolio was 12 months less than the WAL covenant to account for
structural and reinvestment conditions after the reinvestment
period. These include passing the over-collateralisation and Fitch
'CCC' limitation tests, and a WAL covenant that progressively steps
down over time, both before and after the end of the reinvestment
period. In Fitch's opinion, these conditions reduce the effective
risk horizon of the portfolio during stress periods.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A 25% increase of the mean default rate (RDR) across all ratings
and a 25% decrease of the recovery rate (RRR) across all ratings of
the current portfolio would have no impact on the class X-R, A-1-R
and A-2-R notes, but would lead to downgrades of no more than one
notch for the class B-R to E-R notes, and to below 'B-sf' for the
class F-R notes.

Downgrades, which are based on the current portfolio, may occur if
the loss expectation is larger than initially assumed, due to
unexpectedly high levels of defaults and portfolio deterioration.
Due to the better metrics and shorter life of the current portfolio
than the stressed-case portfolio, the class B-R, C-R and F-R notes
display a rating cushion of two notches, and the class D-R and E-R
notes have a cushion of three notches.

Should the cushion between the current portfolio and the
stressed-case portfolio be eroded either due to manager trading or
negative portfolio credit migration, a 25% increase of the mean RDR
across all ratings and a 25% decrease of the RRR across all ratings
of the stressed-case portfolio would lead to downgrades of two
notches for the class A-1-R notes, four notches for the class A-2-R
to D-R notes and to below 'B-sf' for the class E-R and F-R notes.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

A 25% reduction of the RDR across all ratings and a 25% increase in
the RRR across all ratings of the stressed-case portfolio would
lead to upgrades of up to three notches for the rated notes, except
for the 'AAAsf' rated notes.

During the reinvestment period, upgrades, which are based on the
stressed-case portfolio, may occur on better-than-expected
portfolio credit quality and a shorter remaining WAL test, allowing
the notes to withstand larger-than-expected losses for the
remaining life of the transaction.

After the end of the reinvestment period, upgrades, except for the
'AAAsf' notes, may result from a stable portfolio credit quality
and deleveraging, leading to higher credit enhancement and excess
spread available to cover losses in the remaining portfolio.

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

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset pool
and the transaction. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

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.

ESG CONSIDERATIONS

Fitch does not provide ESG relevance scores for Penta CLO 14 DAC.

In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.




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

CONSUMER TOTTA 2: Fitch Assigns 'BBsf' Final Rating on Cl. D Notes
------------------------------------------------------------------
Fitch Ratings has assigned Gamma, STC S.A. / Consumer Totta 2 final
ratings.

The final rating on the class C notes is one notch higher than the
expected rating, mainly driven by the lower final coupon rates
payable to the noteholders and the lower interest rate payable to
the swap provider than initially considered in the analysis. The
final ratings on the class A, B and D notes are the same as their
expected ratings.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
Consumer Totta 2

   A PTGAMMOM0028   LT AA-sf New Rating   AA-(EXP)sf
   B PTGAMNOM0027   LT Asf   New Rating   A(EXP)sf
   C PTGAMOOM0026   LT BBBsf New Rating   BBB-(EXP)sf
   D PTGAMPOM0017   LT BBsf  New Rating   BB(EXP)sf
   E PTGAMQOM0016   LT NRsf  New Rating
   F PTGAMROM0015   LT NRsf  New Rating
   R PTGAMSOM0022   LT NRsf  New Rating
   X PTGAMTOM0013   LT NRsf  New Rating

Transaction Summary

The transaction is a five-month revolving securitisation of a
portfolio of unsecured consumer loans originated in Portugal by
Banco Santander Totta S.A. (Totta; A-/Stable/F2). Totta is
ultimately owned by Banco Santander, S.A. (A-/Stable/F2).

KEY RATING DRIVERS

Asset Assumptions Reflect Riskier Portfolio: The performance of
recent originations reflects Totta's increased risk appetite.
Base-case lifetime default and recovery rates of 8% and 35%,
respectively, were applied, versus 4% and 40% on the Consumer Totta
1 transaction, which closed in 2022. The levels are based on
historical data provided by the originator on the consumer loan
book, on Portugal's economic outlook and on the originator's
underwriting and servicing strategy.

Loans to Employees: The initial portfolio includes a portion of
loans (4.9%) granted to Totta employees. The Portuguese legal
framework does not allow set-off on the loans after their
assignment to the securitisation and the seller commits to
indemnify the special-purpose vehicle (SPV) for any employee loan
set-off claims.

Fitch regards the inclusion of Totta employee loans as non-standard
and risk-increasing, particularly in the short term. This risk
arises from potential employee claims against the originator and
possible losses if the originator becomes insolvent. Fitch
accounted for the presence of employee loans when setting its
'AAAsf' default multiple assumption at 4.75x compared with 4.25x on
Totta 1.

Short Revolving Period: The transaction features a maximum
five-month revolving period compared with 12 months on the Totta 1
transaction. This is the transaction's primary protection against
the risk of further deterioration in asset quality as early
amortisation triggers, linked to principal deficiency ledger (PDL),
cumulative defaults and concentration limits, are viewed as loose.

Sequential Amortisation Triggers: The class A to E notes pay
quarterly and amortise pro-rata from the end of the revolving
period, unless a sequential amortisation event occurs. The switch
to sequential amortisation will occur if the PDL and cumulative
defaults triggers are breached, or when only 10% of the initial
portfolio balance remains. Under its base case a switch to
sequential amortisation is probable in the medium term due to the
triggers and, in particular, because the PDL on the class E notes,
which do not benefit from over-collateralisation.

Interest Rate Mismatch Mitigated: Hedging in the form of a
fixed-to-floating interest rate swap is included in the transaction
to address the mismatch between the floating-rate liabilities and
mainly fixed-rate assets, which are 94.1% of the initial portfolio.
The SPV pays a fixed rate and receives three-month Euribor. The
remaining 5.9% of the assets are linked to 12m Euribor, and while
it is not the same index as for the notes, the two are closely
related. Fitch therefore views basis risk as non-material to the
ratings.

Counterparty Remedies Cap Ratings: The transaction account bank's
(TAB) minimum ratings are set at 'A-' or 'F1', which under Fitch's
Counterparty Rating Criteria can support ratings up to the 'AAsf'
category, resulting in a maximum achievable rating for the
transaction of 'AA+sf'.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- Long-term asset performance deterioration such as increased
defaults and delinquencies or reduced portfolio yield, which could
be driven by changes in portfolio characteristics, macroeconomic
conditions, business practices or legislative landscape.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in upside and
downside environments. The results below should only be viewed as
one potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
future performance.

Sensitivity to Increased Defaults:

Current ratings (class A/B/C/D): 'AA-sf' / 'Asf' / 'BBBsf' /
'BBsf'

Increase defaults by 10%: 'A+sf' / 'A-sf' / 'BBB-sf' / 'BBsf

Increase defaults by 25%: 'Asf' / 'BBB+sf' / 'BB+sf' / 'BB-sf

Increase defaults by 50%: 'BBB+sf' / 'BBBsf' / 'BBsf' / 'B+sf

Sensitivity to Reduced Recoveries:

Reduce recoveries by 10%: 'AA-sf' / 'A-sf' / 'BBB-sf' / 'BBsf'

Reduce recoveries by 25%: 'A+sf' / 'A-sf' / 'BBB-sf' / 'BBsf'

Reduce recoveries by 50%: 'Asf' / 'BBB+sf' / 'BB+sf' / 'B+sf'

Sensitivity to Increased Defaults and Reduced Recoveries:

Increase defaults by 10%, reduce recoveries by 10%: 'A+sf' / 'A-sf'
/ 'BBB-sf' / 'BBsf'

Increase defaults by 25%, reduce recoveries by 25%: 'A-sf' /
'BBB+sf' / 'BBsf' / 'Bsf'

Increase defaults by 50%, reduce recoveries by 50%: 'BBBsf' /
'BB+sf' / 'Bsf' / 'NRsf'

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- For the senior notes, modified TAB and derivative provider
minimum eligibility rating thresholds that are compatible with
'AAAsf' ratings as under Fitch's Structured Finance and Covered
Bonds Counterparty Rating Criteria

- Increases in credit enhancement ratios, allowing the transaction
to absorb credit losses and cash flow stresses at higher ratings

Sensitivity to Reduced Defaults and Increased Recoveries:

Reduce defaults by 10%, increase recoveries by 10%: 'AAsf' / 'A+sf'
/ 'BBB+sf' / 'BBB-sf'

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

Fitch reviewed the results of a third-party assessment conducted on
the asset portfolio information, and concluded that there were no
findings that affected the rating analysis.

Fitch conducted a review of a small targeted sample of the
originator's origination files and found the information contained
in the reviewed files to be adequately consistent with the
originator's policies and practices and the other information
provided to the agency about the asset portfolio.

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.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.




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

TURKIYE WEALTH: Fitch Hikes LongTerm IDRs to 'BB-', Outlook Stable
------------------------------------------------------------------
Fitch Ratings has upgraded Turkiye Wealth Fund's (TWF) Long-Term
Foreign- and Local-Currency Issuer Default Ratings (IDRs) to 'BB-'
from 'B+'. The Outlook is Stable. Fitch has also upgraded TWF's
senior unsecured notes to 'BB-' from 'B+'.

The National Rating (NR) is unaffected by these rating actions and
may be reviewed if and once its NR equivalency analysis results in
different relative creditworthiness across Turkish issuers.

Key Rating Drivers

The rating actions follow the upgrade of Turkiye's sovereign
ratings, as TWF's ratings are equalised with those of the Turkiye
(BB-/Stable) and hence are sensitive to any action on the sovereign
ratings.

Derivation Summary

Under its Government-Related Entities (GRE) Rating Criteria, Fitch
classifies TWF as a GRE of the Turkish government and equalises its
ratings with those of the sovereign. This reflects Fitch's view of
'Virtually Certain' extraordinary support from Turkiye to TWF, if
needed.

Fitch's assessment of 'Very Strong' decision-making and oversight,
preservation of government policy role and contagion risk, and
'Strong' precedents of support leads to an overall government
support score of 55 out of a maximum 60. This warrants an
equalisation of TWF's IDRs with those of Turkiye irrespective of
the Standalone Credit Profile assessment (SCP; b).

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- A downgrade of the sovereign would lead to a downgrade of TWF.

- A weaker assessment of the overall support factors leading to a
score below 45 under its GRE Criteria could lead to a downgrade.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- An upgrade of the sovereign would lead to a similar rating action
on TWF, provided that support factors are unchanged.

Issuer Profile

TWF is Turkiye's sole sovereign wealth fund and manages key
state-owned companies on behalf of the government to promote the
national economy. TWF's portfolio includes 31 companies, two
licenses and 46 real estate properties in seven sectors. Its 31
companies operate mainly in financial services, telecommunications
and technology, transportation and aviation, energy and mining, and
agriculture and food. At end-2023, TWF's total consolidated assets
accounted for about 36% of national GDP.

Public Ratings with Credit Linkage to other ratings

TWF's ratings are credit-linked to Turkish sovereign ratings.

ESG Considerations

Fitch does not provide ESG relevance scores for Turkiye Wealth
Fund.

In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.

   Entity/Debt                Rating           Prior
   -----------                ------           -----
Turkiye Wealth Fund   LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B

   senior unsecured   LT        BB- Upgrade    B+


[*] Fitch Hikes IDRs on 8 Turkish Local/Regional Governments to BB-
-------------------------------------------------------------------
Fitch Ratings has upgraded the Metropolitan Municipalities of
Ankara, Antalya, Bursa, Istanbul, Izmir, Manisa, Mersin and Mugla's
Long-Term Foreign- and Local-Currency Issuer Default Ratings (IDRs)
to 'BB-' from 'B+'. The Outlooks are Stable.

Fitch has also upgraded Istanbul's senior unsecured rating to 'BB-'
from 'B+'.

Under applicable credit rating agency (CRA) regulations, the
publication of local and regional government (LRG) reviews is
subject to restrictions and must take place according to a
published schedule, except where it is necessary for CRAs to
deviate from the schedule in order to comply with the CRAs'
obligation to issue credit ratings based on all available and
relevant information and disclose credit ratings in a timely
manner.

Fitch interprets this provision as allowing us to publish a rating
review in situations where there is a material change in the
creditworthiness of the issuer that Fitch believes makes it
inappropriate for us to wait until the next scheduled review date
to update the rating or Outlook/ Watch status.

The next review dates on Ankara, Antalya, Bursa, Istanbul, Izmir,
Manisa, Mersin and Mugla will be in 2025, but Fitch believes the
developments for the issuers warrant such a deviation from the
calendar and its rationale for this is set out in the first part
(High weight factors) of the Key Rating Drivers section below.
Konya's IDRs are not capped by the sovereign; therefore, its
ratings are unaffected by the sovereign rating action. Fitch will
review Konya at the next scheduled review in 2025.

The National Ratings (NRs) are unaffected by the rating actions and
may be reviewed if its NR equivalency analysis results in different
relative creditworthiness across Turkish issuers.

Key Rating Drivers

HIGH

Sovereign Cap

The upgrade of the IDRs of the eight Turkish LRGs follows the
recent upgrade of Turkiye's sovereign ratings, as the ratings of
the LRGs are capped by the sovereign ratings. The Stable Outlook
reflects that on the sovereign.

Turkish LRGs cannot be rated above the sovereign due to high fiscal
interdependence between the central government and the Turkish
subnationals. The eight Turkish LRGs' IDRs remain capped by those
of the sovereign.

LOW

Risk Profile: Weaker

Fitch's International LRG Rating Criteria envisages 'Vulnerable'
risk profiles for sovereigns rated in the 'B' category or below.
Turkiye's ratings are now in the 'BB' category so do not correspond
with 'Vulnerable' risk profiles. Fitch has consequently reassessed
the risk profiles of Antalya, Bursa, Istanbul, Izmir, Manisa and
Mersin to 'Weaker' from 'Vulnerable'. Mugla and Ankara's risk
profiles are unchanged at 'Weaker'.

The assessment reflects Fitch's view that there is a high risk of
the issuers' ability to cover debt service with the operating
balance weakening unexpectedly over the scenario horizon
(2024-2028) due to lower revenue, higher expenditure, or an
unexpected rise in liabilities or debt service requirements.

The Financial Profile (FP) scores are unchanged at 'aaa' for all
eight Turkish LRGs. The revised Risk Profiles combined with
unchanged FP scores have led us to revise up the Standalone Credit
Profiles (SCP) of Antalya, Bursa, Istanbul, Izmir, Manisa and
Mersin to 'bbb-'. Fitch will reassess SCPs based on peer comparison
at their next annual reviews in 2025.The SCPs have been revised as
follows:

Antalya's SCP raised to 'bbb-' from 'bb+'

Bursa's SCP raised to 'bbb-' from 'bb+'

Istanbul's SCP raised to 'bbb-' from 'bb'

Izmir's SCP raised to 'bbb-' from 'bb'

Manisa's SCP raised to 'bbb-' from 'bb+'

Mersin's SCP raised to 'bbb-' from 'bb-'

Ankara's bbb' SCP 'and Mugla's 'bbb+' SCP are unaffected.

Derivation Summary

The SCPs reflect a combination of 'Weaker' risk profiles and FPs
assessed in the 'aaa' category. Their IDRs are capped by the
Turkish sovereign IDRs.

In its assessment Fitch does not apply extraordinary support from
the upper-tier government or asymmetric risk.

Key Assumptions

Qualitative assumptions and assessments and their respective change
since their last reviews on August 2, 2024 and August 16, 2024 and
weight in the rating decision are as follows:

Ankara and Mugla

Risk Profiles: 'Weaker/ Unchanged with Low Weight'

Revenue Robustness: 'Midrange/ Unchanged with Low Weight'

Revenue Adjustability: 'Weaker/ Unchanged with Low Weight'

Expenditure Sustainability: 'Weaker/ Unchanged with Low Weight'

Expenditure Adjustability: 'Midrange/ Unchanged with Low Weight'

Liabilities and Liquidity Robustness: 'Midrange/ Unchanged with Low
Weight'

Liabilities and Liquidity Flexibility: 'Weaker/ Unchanged with Low
Weight'

Financial Profile: 'aaa' category, Unchanged with Low Weight'

Budget Loans (Notches): N/A, Unchanged with Low Weight

Ad-Hoc Support (Notches): N/A, Unchanged with Low Weight

Asymmetric Risk: 'N/A, Unchanged with Low Weight'

Rating Cap (LT IDR): 'BB-, raised with High Weight'

Rating Cap (LT LC IDR): 'BB-, raised with High Weight'

Rating Floor: 'N/A, Unchanged with Low weight'

Quantitative assumptions - issuer-specific: 'Unchanged with Low
Weight'

Antalya, Bursa, Istanbul, Izmir, Manisa and Mersin

Risk Profiles: 'Weaker/ Raised with Medium Weight'

Revenue Robustness: 'Midrange/ Unchanged with Low Weight'

Revenue Adjustability: 'Weaker/ Unchanged with Low Weight'

Expenditure Sustainability: 'Weaker/ Unchanged with Low Weight'

Expenditure Adjustability: 'Midrange/ Unchanged with Low Weight'

Liabilities and Liquidity Robustness: 'Weaker/ Unchanged with Low
Weight'

Liabilities and Liquidity Flexibility: 'Weaker/ Unchanged with Low
Weight'

Financial Profile: 'aaa' category, Unchanged with Low Weight'

Budget Loans (Notches): N/A, Unchanged with Low Weight

Ad-Hoc Support (Notches): N/A, Unchanged with Low Weight

Asymmetric Risk: 'N/A, Unchanged with Low Weight'

Rating Cap (LT IDR): 'BB-, raised with High Weight'

Rating Cap (LT LC IDR): 'BB-, raised with High Weight'

Rating Floor: 'N/A, Unchanged with Low weight'

Quantitative assumptions - issuer-specific: 'Unchanged with Low
Weight'

Fitch's rating case scenario is a "through-the-cycle" scenario,
which incorporates a combination of revenue, cost and financial
risk stresses. It is based on 2019-2023 figures and 2024-2028
projected ratios.

Quantitative assumptions - sovereign-related (note that no weights
and changes since the last review are included as none of these
assumptions were material to the rating action)

Figures as per Fitch's sovereign data for 2023 and forecast for
2026, respectively:

- GDP per capita (US dollar, market exchange rate): 12,607; 16,978

- Real GDP growth (%): 5.1; 3.7

- Consumer prices (annual average % change): 53.4; 19.4

- General government balance (% of GDP): -5.3; -2.8

- General government debt (% of GDP): 29.3; 26.8

- Current account balance plus net FDI (% of GDP): -3.7; -1.5

- Net external debt (% of GDP): 14.8; 15.5

- IMF Development Classification: EM (emerging market)

- CDS Market-Implied Rating: 'B+'

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A downgrade of the Turkish sovereign IDRs or a downward revision of
an issuer's SCP resulting from a debt payback of more than 9x on a
sustained basis would lead to a downgrade of the issuer's IDRs.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

An upgrade of the Turkish sovereign IDRs would lead to upgrades of
the issuers' IDRs, provided that they maintain their debt payback
ratios below 5x under Fitch's rating case.

Committee date: September 25, 2024

There was an appropriate quorum at the committee and the members
confirmed that they were free from recusal. It was agreed that the
data was sufficiently robust relative to its materiality. During
the committee no material issues were raised that were not in the
original committee package. The main rating factors under the
relevant criteria were discussed by the committee members. The
rating decision as discussed in this rating action commentary
reflects the committee discussion.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

Public Ratings with Credit Linkage to other ratings

The issuers' IDRs are capped by the Turkish sovereign IDRs.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                Rating           Prior
   -----------                ------           -----
Ankara Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+

Mersin Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B

Izmir Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B

Manisa Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B

Istanbul Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
   senior unsecured   LT        BB- Upgrade    B+

Mugla Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+

Bursa Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B

Antalya Metropolitan
Municipality          LT IDR    BB- Upgrade    B+
                      ST IDR    B   Affirmed   B
                      LC LT IDR BB- Upgrade    B+
                      LC ST IDR B   Affirmed   B




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

AMPHORA FINANCE: GBP301MM Bank Debt Trades at 58% Discount
----------------------------------------------------------
Participations in a syndicated loan under which Amphora Finance Ltd
is a borrower were trading in the secondary market around 42.1
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The GBP301 million Term loan facility is scheduled to mature on
June 2, 2025. The amount is fully drawn and outstanding.

Amphora Finance Limited operates as a special purpose entity. The
Company was formed for the purpose of issuing debt securities to
repay existing credit facilities, refinance indebtedness, and for
acquisition purposes. The Company's country of domicile is the
United Kingdom.

BALLIE EDINBURGH: Quantuma Advisory Named as Joint Administrators
-----------------------------------------------------------------
Ballie Edinburgh Ltd was placed in administration proceedings in
the Court of Session, Edinburgh, Court Number: No P830, and Andrew
Andronikou and Brian Burke of Quantuma Advisory Limited were
appointed as administrators on Sept. 19, 2024.  

Ballie Edinburgh, trading as Ballie Ballerson (Edinburgh), is a
licensed restaurant and bar.

Its registered office is at  272 Bath Street, Glasgow, G2 4JR and
it is in the process of being changed to c/o Quantuma Advisory
Limited, 7th Floor, 20 St Andrew Street, London, EC4A 3AG.  Its
principal trading address is at 14 Forrest Road, Edinburgh, EH1
2QN.

The joint administrators can be reached at:

           Andrew Andronikou
           Brian Burke
           Quantuma Advisory Limited
           7th Floor, 20 St. Andrew Street
           London, EC4A 3AG

For further details, contact:
            
            Darren McEvoy
            Email: darren.mcevoy@quantuma.com
            Tel No: 020 3856 6720


CIEP EPOCH: GBP176MM Bank Debt Trades at 44% Discount
-----------------------------------------------------
Participations in a syndicated loan under which CIEP Epoch Bidco
Ltd is a borrower were trading in the secondary market around 56.2
cents-on-the-dollar during the week ended Friday, Sept. 27, 2024,
according to Bloomberg's Evaluated Pricing service data.

The GBP176 million Term loan facility is scheduled to mature on
December 18, 2024. The amount is fully drawn and outstanding.

CIEP Epoch Bidco Limited operates as a mechanical system
contractor. The Company's country of domicile is the United
Kingdom.

CONSTELLATION AUTOMOTIVE: GBP325MM Bank Debt Trades at 28% Discount
-------------------------------------------------------------------
Participations in a syndicated loan under which Constellation
Automotive Ltd is a borrower were trading in the secondary market
around 72.1 cents-on-the-dollar during the week ended Friday, Sept.
27, 2024, according to Bloomberg's Evaluated Pricing service data.

The GBP325 million Term loan facility is scheduled to mature on
July 16, 2029. The amount is fully drawn and outstanding.

Constellation Automotive Group Limited offers digital used car
marketplace. The Company offers used passenger cars, utility
vehicles, and trucks, as well as provides parts and accessories,
repairs and maintenance, finance, and insurance services. The
Company's country of domicile is the United Kingdom.

CROWN AGENTS: Fitch Affirms 'BB' LongTerm IDR, Outlook Stable
-------------------------------------------------------------
Fitch Ratings has affirmed Crown Agents Bank Limited's (CABK)
Long-Term Issuer Default Rating (IDR) at 'BB' with a Stable Outlook
and its Viability Rating (VR) at 'bb'.

Key Rating Drivers

Concentrated Business Model: CABK's ratings primarily reflect the
bank's niche, growing franchise in foreign exchange (FX) and
payments. It also reflects the bank's small size, business
concentrations and high exposure to non-financial risks due to its
role in facilitating payments to emerging and frontier markets.
Income growth has moderated following changing market conditions in
several key currencies. CABK's VR is one notch below its 'bb+'
implied VR because its business profile has a strong impact on the
VR.

International FX and Payments: Fitch's assessment of CABK's
operating environment considers the bank's focus on international
payments and FX services, including exposures to customers in
higher-risk and volatile markets. Its assessment is supported by
CABK's UK domicile due to a high proportion of total assets being
held in cash at the Bank of England (BoE) and a strong regulatory
environment.

Non-Financial Risk Exposure: CABK's business model gives rise to
operational, settlement and concentration risks. The bank is
susceptible to these risks because of the large size of clients
relative to the small size of the bank. However, they are mitigated
by the high quality of its client base with longstanding
relationships. CABK has been investing in risk management to
accommodate growth and automate controls. Controls have been
effective, but business volumes have grown significantly in recent
years.

Low-Risk Balance Sheet: CABK had no impaired loans at end-2023.
Credit exposures consist largely of cash held at the BoE - at 30%
of total assets at end-2023 - highly rated securities, and small
trade finance exposures. Counterparty concentration is high,
although the counterparties are typically of high quality.

Revenue Concentration: CABK's operating profit fell to 13.8% of
risk-weighted assets (RWAs) in 2023 from 18.6% in 2022, following a
normalisation of revenues in several key currencies in 2H23.
Revenues have in recent years benefited from concentrations in
currencies where there have been market dislocations and high
margins, although the latter has reduced and is weighing on income
growth. Earnings remain small in absolute terms - with operating
profit of GBP60 million in 2023 - and prospects depend on the
execution of the bank's growth strategy and the maintenance of
strong risk controls.

Modest Nominal Capital Buffers: CABK's common equity Tier 1 (CET1)
ratio of 26.4% at end-2023 is high, but has fallen from 33.4% at
end-2022 following a sharp rise in RWAs due to higher credit risk
from an increase in lending volumes to banks and greater
operational risk from higher revenues. CABK's small CET1 base in
absolute terms provides a modest buffer over regulatory
requirements, particularly given the bank's exposure to
non-financial risks and balance-sheet concentrations. Fitch expects
the CET1 ratio to decline, but to remain above 20%, as the bank
grows its balance sheet.

Strong Liquidity; Concentrated Deposits: CABK's funding is
underpinned by a highly concentrated deposit base, mitigated by
longstanding relationships with customers. CABK does not borrow to
finance lending, but offers deposit services to FX and payments
customers to facilitate transaction flows. The highly liquid,
liability-driven balance sheet mitigates the risk of unexpected
large withdrawals.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

CABK's ratings would be downgraded on signs of inadequate or weak
controls, which would increase the risk of large operational
losses, punitive regulatory actions or fines. A material weakening
of the bank's franchise in FX and payments, due for example to
reputational damage, would also be negative for the ratings.

A material weakening in the bank's earnings and profitability
prospects, for example through materially weaker business volume
growth, would also put pressure on the ratings.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

An upgrade would require a significant strengthening of the bank's
business profile, scale and competitive advantages, while also
reducing balance-sheet and revenue concentrations. An upgrade would
also require a materially larger capital base to provide a greater
absolute buffer against risks. Strong and sustained revenue growth,
along with robust risk controls against higher business volumes,
would also support an upgrade.

The Government Support Rating (GSR) of 'no support' reflects
Fitch's view that senior creditors cannot rely on extraordinary
support from the UK authorities if the bank becomes non-viable. In
its opinion, the UK has implemented legislation and regulations
that provide a framework requiring senior creditors to participate
in losses for resolving even medium-sized and large banking
groups.

Fitch believes that while CABK may receive support from its
majority shareholder, this cannot be relied on.

Fitch does not expect changes to the GSR given the low systemic
importance of the bank and because of the current legislation in
place that is likely to require senior creditors to participate in
losses.

VR ADJUSTMENTS

The VR of 'bb' is below the 'bb+' implied VR due to the following
adjustment reason: business profile (negative).

The 'bbb+' operating environment score is below the 'aa' category
implied score due to the following adjustment reason: international
operations (negative)

The 'bbb' asset quality score is below the 'a' category implied
score due to the following adjustment reasons: concentrations
(negative) and non-loan exposure (negative)

The 'bb' earnings and profitability score is below the 'a' category
implied score due to the following adjustment reasons: risk weight
calculation (negative) and revenue diversification (negative)

The 'bb-' capitalisation & leverage score is below the 'a' category
implied score due to the following adjustment reasons: size of
capital base (negative) and risk profile and business model
(negative)

The 'bbb-' funding & liquidity score is below the 'a' category
implied score due to the following adjustment reasons: deposit
structure (negative) and non-deposit funding (negative)

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                        Rating         Prior
   -----------                        ------         -----
Crown Agents Bank
Limited             LT IDR             BB Affirmed   BB
                    ST IDR             B  Affirmed   B
                    Viability          bb Affirmed   bb
                    Government Support ns Affirmed   ns


EUROSAIL 2006-1: S&P Lowers Class D1a Notes Rating to 'B(sf)'
-------------------------------------------------------------
S&P Global Ratings lowered to 'B (sf)' from 'BB (sf)' its ratings
on Eurosail 2006-1 PLC's class D1a and D1c notes and to 'B-(sf)'
from 'B (sf)' its rating on the class E notes. At the same time,
S&P affirmed its 'A+ (sf)' ratings on the class B1a, B1c, C1a, and
C1c notes.

Since S&P's previous review, the transaction's performance has
deteriorated. Arrears, as per the June 2024 investor report, have
increased to 29.8% from 20.44%. The percentage increase in arrears
mostly reflects the reduced pool size rather than the actual rise
in arrears.

Cumulative losses have increased marginally to 4.27% from 4.26% at
our previous review.

S&P's weighted-average foreclosure frequency assumptions have
increased at all rating levels, reflecting higher arrears. This has
been partially offset by lower weighted-average loss severity
assumptions, stemming from a decrease in the current loan-to-value
ratio following house price index growth. However, considering the
transaction's historical loss severity levels, the latest available
data suggests that the portfolio's underlying properties may have
only partially benefited from rising house prices, and S&P has
therefore applied a haircut to property valuations to reflect
this.

Weighted-average foreclosure frequency and weighted-average loss
severity

             WAFF (%)  WALS (%)  CREDIT COVERAGE (%)

  AAA        47.84     22.68     10.85

  AA         42.78     16.50     7.06

  A          39.81     7.66      3.05

  BBB        36.64     3.89      1.43

  BB         33.37     2.06      0.69

  B          32.54     2.00      0.65

WAFF--Weighted-average foreclosure frequency.
WALS--Weighted-average loss severity.

The reserve fund is at target and not amortizing due to the breach
in the 90+ days arrears and cumulative losses triggers. Given the
transaction's sequential amortization, credit enhancement has
increased since S&P's previous review, which is partially
offsetting the deterioration in performance in our cash flow
analysis.

Like other Eurosail transactions, both fixed and floating fees for
this deal have increased above their historical averages. These
elevated expenses are attributable to legal complexities arising
from the LIBOR transition. Consequently, S&P's anticipate a decline
in fees moving forward and have incorporated various fee scenarios
into our cash flow analysis.

S&P said, "Our cash flow modelling shows that the class B1a to C1c
notes pay timely interest and repay principal at rating levels
above 'A+'. However, our counterparty criteria cap the notes at our
'A+' long-term issuer credit rating on Barclays Bank PLC. We
therefore affirmed our 'A+ (sf)' ratings on these notes.

"We lowered to 'B (sf)' from 'BB (sf)' our ratings on the class D1a
and D1c notes. The assigned ratings are in line with the levels
indicated by our cash flow results, and also factor in the notes'
sensitivity to increased arrears (resulting in higher defaults and
longer recoveries), the borrowers' credit profile, the high
interest rate environment, and tail-end risk associated with the
small pool size.

"The class E1c notes do not achieve any rating in our standard or
steady state scenario (actual fees, expected prepayment, no spread
compression, and no commingling stress) cash flow runs. Given the
positive credit enhancement, the non-amortizing reserve fund,
potential improving macroeconomic environment for non-conforming
borrowers due to lower interest rates, and likelihood that arrears
are close to peaking, we consider repayment of this class as not
dependent upon favorable business, financial, and economic
conditions. However, the last 12 months have been challenging given
the borrowers' non-conforming nature, considering their higher
exposure to inflationary pressures. As a result, arrears have
significantly increased and affected this tranche's performance. We
therefore lowered our rating to 'B- (sf)' from 'B (sf)'.

"We consider the transaction's resilience in case of additional
stresses to some key variables, in particular defaults and loss
severity, to determine our forward-looking view. We considered the
sensitivity of the ratings to increased defaults, extended
recoveries, and higher interest rates, and the ratings remain
robust. Given its high seasoning (221 months), the transaction has
a low pool factor (7.37%), which tends to amplify movement in
arrears. We have considered the tail-end risk associated with the
low pool factor in our analysis."

Macroeconomic forecasts and forward-looking analysis

S&P said, "We expect interest rates in the U.K. to remain higher
for longer than previously expected.

"We consider the borrowers in this transaction to be nonconforming
and as such generally less resilient to higher interest rates than
prime borrowers. All the borrowers are currently paying a floating
rate of interest and will be affected by higher rates. In our view,
the ability of the borrowers to repay their mortgage loans will be
highly correlated to macroeconomic conditions and the complex
profile of nonconforming borrowers.

"Given our current macroeconomic forecasts and forward-looking view
of the U.K. residential mortgage market, we have performed
additional sensitivities related to higher levels of defaults due
to increased arrears and house price declines. We have also
performed additional sensitivities with extended recovery timings
due to observed repossession delays owing to court backlogs in the
U.K. and the repossession grace period under the Mortgage Charter.
The results of the additional sensitivities were in line with the
ratings assigned."

This transaction is backed by nonconforming U.K. residential
mortgages originated by Southern Pacific Mortgage Ltd. and Southern
Pacific Personal Loans Ltd. in May 2006.


EUROSAIL 2006-3NC: S&P Cuts Rating on D1a & D1c Notes to 'B(sf)'
----------------------------------------------------------------
S&P Global Ratings lowered to 'B (sf)' from 'BB- (sf)' its ratings
on Eurosail 2006-3NC PLC's class D1a and D1c notes. At the same
time, S&P affirmed its 'A+ (sf)' ratings on the class B1a, C1a, and
C1c notes, and its 'B- (sf)' rating on the class E1c notes.

Since S&P's previous review, the transaction's performance has
deteriorated. Arrears, as per the June 2024 investor report, have
increased to 40.18% from 31.25%. The percentage increase in arrears
mostly reflects the reduced pool size rather than the actual
increase in arrears.

Cumulative losses have increased marginally to 4.41% from 4.4% at
S&P's previous review.

S&P said, "Our weighted-average foreclosure frequency assumptions
have increased at all rating levels, reflecting higher arrears.
This has been partially offset by lower weighted-average loss
severity assumptions, stemming from a decrease in the current
loan-to-value ratio following house price index growth. However,
considering the transaction's historical loss severity levels, the
latest available data suggests that the portfolio's underlying
properties may have only partially benefited from rising house
prices, and we have therefore applied a haircut to property
valuations to reflect this."

Weighted-average foreclosure frequency and weighted-average loss
severity

            WAFF (%)  WALS (%)  CREDIT COVERAGE (%)

  AAA       58.33     24.96     14.56

  AA        54.52     19.01     10.37

  A         51.89     10.48      5.44

  BBB       48.90      6.34      3.10

  BB        45.80      4.04      1.85

  B         45.02      2.45      1.10

WAFF--Weighted-average foreclosure frequency.
WALS--Weighted-average loss severity.

The reserve fund is at target and not amortizing due to the breach
in the 90+ days arrears and cumulative losses triggers. The
liquidity facility is at target and is also not amortizing. Given
the transaction's sequential amortization, credit enhancement has
increased since S&P's previous review, which is partially
offsetting the deterioration in performance in its cash flow
analysis.

Like other Eurosail transactions, both fixed and floating fees for
this deal have increased above their historical averages. These
elevated expenses are attributable to legal complexities arising
from the LIBOR transition. Consequently, S&P anticipates a decline
in fees moving forward and have incorporated various fee scenarios
into its cash flow analysis.

S&P said, "Our cash flow modelling shows that the class B1a to C1c
notes pay timely interest and repay principal at rating levels
above 'A+'. However, our counterparty criteria cap the notes at our
'A+' long-term issuer credit rating on Barclays Bank PLC. We
therefore affirmed our 'A+ (sf)' ratings on these notes.

"We lowered to 'B (sf)' from 'BB- (sf)' our ratings on the class
D1a and D1c notes. The assigned ratings are in line with the levels
indicated by our cash flow results, and also factor in the notes'
sensitivity to increased arrears (resulting in higher defaults and
longer recoveries), the borrowers' credit profile, the high
interest rate environment, and tail-end risk associated with the
small pool size.

"The class E1c notes do not achieve any rating in our standard or
steady state scenario (actual fees, expected prepayment, no spread
compression, and no commingling stress) cash flow runs. Given the
positive credit enhancement, the non-amortizing reserve fund,
potential improving macroeconomic environment for non-conforming
borrowers due to lower interest rates, and likelihood that arrears
are close to peaking, we consider repayment of this class as not
dependent upon favorable business, financial, and economic
conditions. Therefore, we affirmed our 'B- (sf)' rating.

"We consider the transaction's resilience in case of additional
stresses to some key variables, in particular defaults and loss
severity, to determine our forward-looking view. We considered the
sensitivity of the ratings to increased defaults, extended
recoveries, and higher interest rates, and the ratings remain
robust. Given its high seasoning (217 months), the transaction has
a low pool factor (9.41%), which tends to amplify movement in
arrears. We have considered the tail-end risk associated with the
low pool factor in our analysis."

Macroeconomic forecasts and forward-looking analysis

S&P said, "We expect interest rates in the U.K. to remain higher
for longer than previously expected.

"We consider the borrowers in this transaction to be nonconforming
and as such generally less resilient to higher interest rates than
prime borrowers. All the borrowers are currently paying a floating
rate of interest and will be affected by higher rates. In our view,
the ability of the borrowers to repay their mortgage loans will be
highly correlated to macroeconomic conditions and the complex
profile of nonconforming borrowers.

"Given our current macroeconomic forecasts and forward-looking view
of the U.K. residential mortgage market, we have performed
additional sensitivities related to higher levels of defaults due
to increased arrears and house price declines. We have also
performed additional sensitivities with extended recovery timings
due to observed repossession delays owing to court backlogs in the
U.K. and the repossession grace period under the Mortgage Charter."
The results of the additional sensitivities were in line with the
ratings assigned.

Eurosail 2006-3NCL's loan pool comprises first- and second-ranking
mortgages on properties in England, Wales, and Northern Ireland,
and standard securities on properties in Scotland. This transaction
is backed by nonconforming U.K. residential mortgages originated by
Southern Pacific Mortgage Ltd. and Southern Pacific Personal Loans
Ltd. in November 2006.


EUROSAIL-UK 2007-3BL: S&P Lowers Cl. E1c Notes Rating to 'CCC(sf)'
------------------------------------------------------------------
S&P Global Ratings lowered to 'CCC (sf)' from 'B- (sf)' its rating
on Eurosail-UK 2007-3BL PLC's class E1c notes. At the same time,
S&P affirmed its 'AA+ (sf)' ratings on the class A3a and A3c notes,
its 'A+ (sf)' ratings on the class B1a and B1c notes, its 'B (sf)'
ratings on the class C1a and C1c notes, and its 'B- (sf)' rating on
the class D1a notes.

Since S&P's previous review, the transaction's performance has
deteriorated. Arrears, as per the June 2024 investor report, have
increased to 31.4% from 23.03%. The percentage increase in arrears
mostly reflects the reduced pool size rather than the actual
increase in arrears.

Cumulative losses have increased marginally to 4.47% from 4.4% at
S&P's previous review.

S&P said, "Our weighted-average foreclosure frequency assumptions
have increased at all rating levels, reflecting higher arrears.
This has been partially offset by lower weighted-average loss
severity assumptions, stemming from a decrease in the current
loan-to-value ratio following house price index growth. However,
considering the transaction's historical loss severity levels, the
latest available data suggests that the portfolio's underlying
properties may have only partially benefited from rising house
prices, and we have therefore applied a haircut to property
valuations to reflect this."

Weighted-average foreclosure frequency and weighted-average loss
severity

            WAFF (%)  WALS (%)  CREDIT COVERAGE (%)

  AAA       61.61     31.00     19.10

  AA        54.61     23.99     13.10

  A         50.60     13.77      6.97

  BBB       46.22      8.75      4.04

  BB        41.64      5.93      2.47

  B         40.50      3.93      1.59

WAFF--Weighted-average foreclosure frequency.
WALS--Weighted-average loss severity.

The reserve fund is at target and not amortizing due to the breach
in the 90+ days arrears and cumulative losses triggers. Given the
transaction's sequential amortization, credit enhancement has
increased since S&P's previous review, which is partially
offsetting the deterioration in performance in its cash flow
analysis.

Like other Eurosail transactions, both fixed and floating fees for
this deal have increased above their historical averages. These
elevated expenses are attributable to legal complexities arising
from the LIBOR transition. Consequently, S&P anticipates a decline
in fees moving forward and have incorporated various fee scenarios
into our cash flow analysis.

S&P said, "Our cash flow modelling shows that the class A3a to A3c
notes pay timely interest and repay principal at rating levels
above 'AA+'. However, our assigned ratings also reflect the
significant increase in arrears and fixed fees, the low pool
factor, and the high percentage of interest-only loans with
tail-end risk. We therefore affirmed our 'AA+ (sf)' ratings.

"Compared to our last review, the class B1a and B1c notes' cash
flow results have deteriorated, given the declining performance of
the pool. However, the results are still in line with the assigned
ratings. We therefore affirmed our 'A+ (sf)' ratings.

"The class C1a, C1c, and D1a notes' cash flow results have
deteriorated. However, the class C1a and C1c notes could benefit
from significantly higher hard credit enhancement compared to the
class D1a notes. Therefore, we affirmed our 'B (sf)' ratings on the
class C1a and C1c notes, and our 'B- (sf)' rating on the class D1a
notes.

"We lowered to 'CCC (sf)' from 'B- (sf)' our rating on the class
E1c notes. The assigned rating reflects our cash flow results. The
rating also considers the notes' sensitivity to increased arrears
(resulting in higher defaults and longer recoveries), the
borrowers' credit profile, the high interest rate environment, and
tail-end risk associated with the small pool size.

"The class E1c notes do not achieve any rating in our standard or
steady state scenario (actual fees, expected prepayment, no spread
compression, and no commingling stress) cash flow runs with high
principal failures. The last 12 months has been challenging given
the borrowers' non-conforming nature, considering their higher
exposure to inflationary pressures.

"We consider this tranche to be currently vulnerable and dependent
upon favourable business, financial, and economic conditions to pay
timely interest and ultimate principal. In line with our 'CCC'
criteria, we lowered our rating to 'CCC (sf)' from 'B- (sf)'.

"We consider the transaction's resilience in case of additional
stresses to some key variables, in particular defaults and loss
severity, to determine our forward-looking view. We considered the
sensitivity of the ratings to increased defaults, extended
recoveries, and higher interest rates, and the ratings remain
robust. Given its high seasoning (211 months), the transaction has
a low pool factor (15.96%), which tends to amplify movement in
arrears. We have considered the tail-end risk associated with the
low pool factor in our analysis."

Macroeconomic forecasts and forward-looking analysis

S&P said, "We expect interest rates in the U.K. to remain higher
for longer than previously expected.

"We consider the borrowers in this transaction to be nonconforming
and as such generally less resilient to higher interest rates than
prime borrowers. All the borrowers are currently paying a floating
rate of interest and will be affected by higher rates. In our view,
the ability of the borrowers to repay their mortgage loans will be
highly correlated to macroeconomic conditions and the complex
profile of nonconforming borrowers.

"Given our current macroeconomic forecasts and forward-looking view
of the U.K. residential mortgage market, we have performed
additional sensitivities related to higher levels of defaults due
to increased arrears and house price declines. We have also
performed additional sensitivities with extended recovery timings
due to observed repossession delays owing to court backlogs in the
U.K. and the repossession grace period under the Mortgage Charter.
The results of the additional sensitivities were in line with the
ratings assigned."

This transaction is backed by nonconforming U.K. residential
mortgages originated by multiple originators in July 2007.


EXTRASPACE SOLUTIONS: Ernst & Young Named as Joint Administrators
-----------------------------------------------------------------
Extraspace Solutions (UK) Limited was placed in administration
proceedings in the High Court Of Justice in Northern Ireland
Chancery Division, Court Number: 28950, and Timothy Graham Vance,
Charles Graham John King, and Andrew Dolliver of Ernst & Young LLP
were appointed as administrators on Sept. 23, 2024.  

Extraspace Solutions engages in the construction of commercial
buildings.

The company's registered office is at The Soloist Building, 1
Lanyon Place, Belfast, Northern Ireland, Northern Ireland, BT1
3LP.

The administrators can be reached at:

            Timothy Graham Vance
            Charles Graham John King
            Ernst & Young LLP
            12 Wellington Place
            Leeds, LS1 4AP

            -- and --

            Andrew Dolliver
            Ernst & Young LLP
            Bedford House
            16 Bedford Street
            Belfast, BT2 7DT


PHION THERAPEUTICS: KPMG Named as Joint Administrators
------------------------------------------------------
Phion Therapeutics Ltd was placed in administration proceedings in
the High Court of Justice in Northern Ireland Chancery Division,
Court Number: No 28942 of 2024, and  James Neill and John Donaldson
of KPMG,were appointed as administrators on Sept. 23, 2024.  

pHion Therapeutics is a UK based biotech delivering ground-breaking
nucleic acid vaccines and therapeutics.

pHion's registered office is at 63 University Road, Research And
Enterprise, Belfast, Antrim, Northern Ireland, BT7 1NF.

The administrators can be reached at:

            James Neill
            John Donaldson
            KPMG
            The Soloist Building
            1 Lanyon Place
            Belfast BT1 3LP
            Tel No: +44 28 9024 3377


SQUARE ROOT: CG&Co Named as Joint Administrators
------------------------------------------------
Square Root London Limited was placed in administration proceedings
in In the High Court of Justice Business and Property Courts in
Manchester, Court Number: CR-2024-MAN-001183, and Edward M
Avery-Gee and Nick Brierley of CG&Co were appointed as
administrators on Sept. 26, 2024.  

Square Root, trading as Square Root Soda, manufactures soft drinks,
and produces mineral waters and other bottled waters.

Its registered office and principal trading address is at Square
Root Soda Works, Unit D11, Leyton Industrial Village, Argall
Avenue, London, E10 7QP.

The administrators can be reached at:

          Edward M Avery-Gee
          Nick Brierley
          CG&Co
          27 Byrom Street, Manchester
          M3 4PF

For further information, contact:
           
           Bill Brandon
           Tel No: 0161 358 0210


WHITE HART: Opus Restructuring Named as Administrators
------------------------------------------------------
The White Hart At Uttoxeter Limited, trading name The White Hart
Hotel, was placed in administration proceedings in the High Court
of Justice, Court Number: CR-2024-004860, and Louise Williams and
Paul Mallatratt of Opus Restructuring LLP were appointed as
administrators on Sept. 10, 2024.  

The White Hart specialized in licensed restaurants.

Its registered office is at 1 Unit X C/O M J Barrett, Brookside
Road, Uttoxeter, Staffordshire, ST14 8AT.  Principal trading is at
The White Hart Hotel, 34-36 Carter St, Uttoxeter ST14 8EU.

The administrators can be reached at:

            Louise Williams
            Paul Mallatratt
            Opus Restructuring LLP
            Bridgford Business Centre
            29 Bridgford Road, West Bridgford
            Nottingham, NG2 6AU

For further information, contact:
           
            The Joint Administrators
            Tel No: 0115 666 8230

Alternative contact: Charlotte Jones



                           *********


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 2024.  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
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delivered via e-mail.  Additional e-mail subscriptions for
members of the same firm for the term of the initial subscription
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