New York, November 08, 2011 — Moody’s Investors Service is requesting comment from market participants on its proposed new methodology for rating securities issued by closed-end funds (CEFs). The new methodology would apply to approximately 240 ratings, representing approximately $28 billion of debt and preferred stock outstanding.

In proposing the new methodology, the rating agency has the following objectives:

(1) to update its guidelines on advance rates used to assess fund leverage to take into account asset volatility of the kind seen during the 2008—09 financial crisis;

(2) to evaluate the quality of funds’ credit and investment processes, as well as the quality and commitment of their management teams, as part of its analysis of CEFs, while using quantitative and qualitative factors;

(3) to establish a set of objective measures that will be used consistently in a composite evaluation of key rating factors for CEFs (e.g. leverage, asset quality and coverage) using standardized metrics; and

(4) to consider adjustments based on qualitative factors, such as liquidity management.

The proposed rating approach will allow us to look not only at the quality of closed-end funds’ assets, but also to evaluate funds’ ability to respect regulatory leverage limits and pay their fixed charges, says Yaron Ernst, Managing Director of Moody’s Managed Investments group.

The proposed methodology follows the unprecedented price volatility and illiquidity seen during the 2008—09 financial crisis, which prompted Moody’s to review its assumptions regarding potential market value declines and the liquidity of CEFs’ underlying assets, as well as the latent risks for investors in securities issued by CEFs in stressed market environments.

Following asset value declines during the crisis, Moody’s says, although many fund managers acted quickly to deleverage their funds to meet their asset coverage ratio thresholds, some were left in temporary breach of those thresholds and suspended common dividends. The differences among CEFs, which the proposed methodology aims to capture, related mainly to the quality and liquidity of funds’ underlying assets and to funds’ capital structures, as well as to managers’ commitment to their business and investors.

Similar to our practice in other sectors, we plan to introduce a scorecard to represent our evaluation of key rating factors using standardized metrics, Ernst says. The rating generated from the scorecard might be adjusted to take into account various qualitative rating factors, and from that baseline assessment, which would be a fund’s senior implied rating, a security could be notched down depending on its priority of claim in the fund’s capital structure.

If implemented, the proposed methodology is expected to result in lower ratings for CEFs generally, with ratings of CEFs that invest in municipal securities typically in the Aa-range, and CEFs invested in other assets such as REITs and equities clustered in the A-range. A substantial portion of the rating downgrades would be driven by positioning preferred stock ratings one notch below a CEF’s senior implied rating, given the large cohort of rated preferred securities in the CEF universe.

The request for comment is titled, Moody’s Proposes New Methodology for Rating Securities Issued by Closed-End Funds and is available on moodys.com. Market participants are encouraged to send their comments to cpc@moodys.com by December 15, 2011. Moody’s will consider comments received up until that time, then will publish a final methodology and begin the process of implementing any associated rating changes.

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Daniel Serrao

Senior Vice President

Managed Investments Group