On September 1, 2010, Fitch announced that it completed implementation of its updated approach to rating structured notes. The Fitch action follows its earlier announcement in May 2010 and similar actions taken by Standard & Poor’s and Moody’s in 2009 and early 2010.

Fitch will withdraw ratings from structured notes with variable principal payments (non-principal-protected notes). The agency also will add a subscript (“emr”) to principal protected notes that it will continue to rate to indicate the particular limitations associated with the rating, which only reflects the assessment of counterparty risk. Fitch further clarified that this new approach relates only to structured products issued directly by financial institution issuers, and does not extend to structured products issued by special purpose entities, unless such issuance benefits from a guarantee by a rated financial institution. Inflation-linked notes also are excluded from this new policy.