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Structured Finance

www.fitchratings.com 13 January 2009

Prime RMBS Belgium New Issue

Belgian Lion N.V./S.A Compartment Belgian Lion RMBS I

Summary This EUR5.33bn securitisation transaction is the first RMBS transaction originated by ING Belgium N.V./S.A. (the originator, ING), rated ‘AA’ Outlook Negative/‘F1+’. ING Belgium became a wholly‐owned subsidiary of ING Group, rated ‘AA‐’ Outlook Negative/‘F1+’ in 1998. Before 2003, ING Belgium was called Banque Bruxelles Lambert (BBL) which was the result of a former merger in June 1975 of Banque de Bruxelles and Banque Lambert.

The portfolio consists of prime Belgian residential mortgage loans secured by residential properties located in Belgium. Each loan benefits from a first‐ranking mortgage registered over a residential property.

The issuer is a special‐purpose company that qualifies as an “institutionele vennootschap voor belegging in schuldvorderingen naar Belgisch recht/société d’investissement en créances institutionnelle de droit belge” (Belgian institutional company for investment in receivables, institutional VBS/SIC) in accordance with the Belgian UCITS Act and was registered as such with the Federal Public Service Finance (Federale Overheidsdienst Financiën/Service Public Fédéral Finances).

Fitch Ratings has assigned a rating to the notes issued by the compartment Belgian Lion RMBS I (the issuer) of Belgian Lion N.V./S.A. as indicated at left. The rating is based on the quality of the collateral, available credit enhancement, a sound legal structure, the underwriting and origination assessment of ING, the interest rate swap and the liquidity facility provided by ING. The ratings address timely payment of interest and ultimate repayment of principal at the legal final maturity of the notes.

Counterparties • Seller: ING Belgium N.V./S.A.

• Arranger: ING Belgium N.V./S.A..

• Servicer: ING Belgium N.V./S.A.

• Interest Rate Swap Counterparty: ING Belgium N.V./S.A.

• Liquidity Facility Provider: ING Belgium N.V./S.A.

• Originator: ING Belgium N.V./S.A.

• Auditors: Ernst & Young

• Administrator/Calculation Agent: ING Belgium N.V./S.A.

• Domiciliary Agent: ING Belgium N.V./S.A.

• Corporate Services Provider: ING Belgium N.V./S.A.

• Security Agent: Stichting Security Agent Belgian Lion, a Dutch Stichting

Ratings

Class Amount (EURm)

Final Maturity Rating CE (%)

A 4,816.00 Nov 2045 AAA 9.65 B 514.50 Nov 2045 NR 0.00

The rated class of notes in this transaction has a Stable Outlook

Closing Update 12 January 2009

Analysts Helene Weintraub Spira +33 1 44 29 91 20 [email protected]

Henri de Mont‐Serrat +33 1 44 29 91 39 [email protected]

Performance Analytics Aksel Etingu +44 20 7682 7135 [email protected]

Structured Finance

Belgian Lion N.V./S.A Compartment Belgian Lion RMBS I January 2009

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Transaction Diagram

Source: Fitch

Noteholders

Interest Rate Swap Counterparty

ING Belgium

Liquidity Facility Provider

GIC Provider

ING Belgium

Security Agent

Stichting Security Agent Belgian Lion

ING Belgium as Seller and Servicer

Sale of Portfolio

Sale proceeds

Note Issuance

Funding Proceeds Servicing Agreement

Belgian Lion N.V./S.A Compartment Belgian

Lion RMBS I

Class A

Class B

Credit Committee Highlights • Counterparty Risk: this transaction strongly relies on the creditworthiness of

ING as counterparty in this transaction, ie swap counterparty. Fitch is currently reviewing its counterparty criteria. Please refer to the press release, “Fitch: Counterparty Criteria for Global Structured Finance under Review”, dated 15 October 2008.

• Revolving Period: at closing, the transaction entered into a five year revolving period. During this period, the issuer shall purchase and accept the assignment of new mortgage receivables from the seller. Some triggers are in place, which would switch the notes to the amortisation period if they were breached. Fitch has determined a post‐revolving pro forma pool with characteristics derived from the revolving period conditions (ie maximum weighted average DTI allowed etc, see Revolving Period section) to analyse the collateral.

• Pari Passu loans: in addition to the mortgage loans securitised, some loans may have been granted by ING under a credit facility or debts may exist before the sale date with an imputation option; these loans are or may become secured by the same mortgage as the mortgage loan. In case of default of the borrower, all his/her loans rank pari passu. Hence, under this scenario, the issuer will need to share recovery proceeds pro rata with ING (in case ING still has on its books loans relating to the defaulted borrower). Fitch took this into consideration in its recovery analysis. Following the revolving period, pari passu loans may amount to 7% of the portfolio. (Note also that loans granted after the transfer date to the issuer will be subordinated by law to the securitised loans.)

• Original Loan‐to‐Value Ratio: some adjustments have been made on the original loan‐to‐value ratio (OLTV) and current LTV (CLTV) calculations, to take into account the specifics of more than one loan being secured by the same mortgage (see Asset Analysis below).

• Credit Enhancement: similarly to other RMBS transactions originated by companies which are part of ING Group in the Netherlands, this transaction structure does not benefit from any excess spread or a reserve fund. At closing, credit enhancement for the class A notes was 9.65% and was provided solely by a subordinated class of notes.

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• Liquidity Facility: the structure benefits from a liquidity facility provided by ING equating to 5% of the initial notes’ balance. The facility is available to meet interest shortfalls on the class A notes.

• Interest Rate Swap: on the closing date, the issuer entered into an interest rate swap with ING to mitigate the risk of a mismatch between the interest to be received by the issuer from the portfolio and the interest payable by the issuer on the notes; the swap pays the interest due on the notes net of principal losses and receives scheduled interest on the loans (excluding defaulted loans). The interest rate swap does not provide excess spread.

Financial Structure The issuer used the net proceeds of the issue of the notes to buy from the seller the initial portfolio of EUR5,330,415,230 (the current balance as of the cut‐off date), constituting 56,899 loans.

Interest on the notes is payable quarterly in arrears on the 25th day of February, May, August and November in each year.

Pre‐Enforcement Priority of Payments The pre‐enforcement priority of payments is applicable, unless an enforcement notice is given. There are quarterly payment dates. Available funds are allocated according to a separate priority of payments.

Interest Priority of Payments On each quarterly payment date, the available interest amount (see below) will be allocated prior to enforcement according to the following priority of payments:

1. senior fees and expenses; 2. liquidity facility (other than (9)); 3. swap default payment (other than (10)); 4. class A interest; 5. class A PDL (PDL recording realised loss); 6. class B interest; 7. class B IDL; 8. class B PDL (PDL recording realised loss); 9. subordinated payments on the liquidity facility; 10. subordinated swap default payment; 11. deferred purchase price to the seller.

The available interest amount comprises of, among others:

1. interest from the loans;

2. interest on the issuer collection account;

3. prepayment penalties and interest penalties on the mortgages;

4. net proceeds of foreclosure procedures (not related to principal);

5. amounts drawn under the liquidity facility;

6. swap counterparty payments;

7. amounts received from the repurchase of mortgage receivables (not related to principal);

8. recoveries on foreclosed loans (not related to principal).

Principal Priority of Payments On each quarterly payment date, the allocation of the principal available amount (see below) is allocated sequentially, first the principal of the class A notes and then the principal of the class B notes.

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The available principal amount comprises, among others:

1. repayment and prepayment of principal under the loans (excluding prepayment penalties);

2. net proceeds on any loan relating to principal;

3. amounts received in connection with a sale or repurchase of loans relating to principal;

4. recoveries to the extent related to principal;

Less (during the revolving period):

an amount equal to the part of the replenishment available amount applied by the issuer to the purchase of new loans, or which the issuer decides to keep on the collection account (with a limit of EUR250m) with a view to purchase new loans after the quarterly payment date.

Following the issuance of an enforcement notice, when the security agent declares the notes to be due and payable, all available funds (interest and principal receipts) will be allocated sequentially to interest and principal payments due under the class A notes and then under the class B notes after the payment of senior fees, the liquidity line, the swap counterparty and certain third‐party expenses.

Liquidity Facility ING is the liquidity facility provider. The 364‐day term liquidity facility amount stands, at closing, at 5.0% of the aggregate initial balance of the notes. The liquidity facility will be used to cover interest shortfalls on the senior notes.

If the liquidity provider rating is downgraded below ‘F1’ or if the liquidity facility is not renewed, then the issuer shall draw the line (unless eg the liquidity facility is replaced by an entity rated at least ‘F1’).

Interest Rate Risk At closing, the issuer entered into an interest rate swap (ISDA) agreement with ING to hedge the risk of a mismatch between the interest to be received from the portfolio and the interest payable on the notes.

Under the swap agreement, the issuer agreed to pay on each quarterly payment date:

a. scheduled interest to be received on the portfolio (on performing loans and loans in arrears for less than three months); plus

b. prepayment penalties received on the portfolio; plus

c. interest received on the issuer collection account; less

d. senior costs and expenses.

The swap counterparty agreed to pay on each quarterly payment date the sum of the scheduled interest due on the notes (less any outstanding debit balance on the PDL).

If the swap counterparty ceases to have certain required ratings by Fitch, the swap counterparty will be required to take certain remedial measures, which may include: (a) the provision of collateral for its obligations under the swap agreement; (b) arranging for its obligations under the swap agreement to be transferred to an entity with the required ratings; (c) arranging to benefit from an unconditional guarantee from an entity having the minimum required ratings; or (d) the taking of such other action as it may agree with Fitch. A failure to take such steps, subject to certain conditions, will give the issuer the right to terminate the swap agreement.

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Please refer to “Counterparty Risk in Structured Finance Transactions: Hedge Criteria”, published 1 August 2007 and available at www.fitchratings.com.

Fitch is currently reviewing its swap counterparty criteria. Please refer to the press release, “Fitch: Counterparty Criteria for Global Structured Finance under Review”, dated 15 October 2008.

Legal Structure The issuer was created under the form of an institutional VBS/SIC with segregated compartments. More specifically, it is an institutionele vennootschap voor belegging in schuldvorderingen naar Belgisch recht/société d’investissement en créances institutionnelle de droit belge in accordance with the UCITS Act and has been licensed by the Commission Bancaire et Financière et des Assurances (CBFA) as a mortgage loan institution.

Mortgage loans are transferred from the seller to the issuer by way of a true sale. No notification to the borrowers is needed to perfect the true sale. However, if certain events occur, the borrowers will be notified of the sale of their mortgage loans and the pledge to the issuer to avoid any set‐off risk or any risk of defences that might be raised by a borrower (see Set‐off Risk and Notification Events below). In the latter case, Fitch believes that the undertaking of the seller to indemnify the issuer and the mechanism of notification in place adequately covers this risk.

Security for the Notes Pursuant to the pledge agreement, the notes are secured by a first‐ranking pledge granted by the issuer to the security agent and the other secured parties over: (i) the mortgage receivables and the related security; (ii) the issuer’s rights under or in connection with the documents; and (iii) the balances standing to the credit of the issuer’s accounts.

The security agent, Stichting Security Agent Belgian Lion, is organised as a Stichting (a foundation) under Dutch law. It will represent the interests of the holders of the notes, hold the security granted under the pledge agreement on behalf of the secured parties and will be entitled to enforce the security granted in its favour under the pledge agreement as creditor under the parallel debt and under the UCITS act. This parallel debt has been granted by the issuer in favour of the security agent to secure the valid creation of the security in favour of the security agent and the other secured creditors.

The pledge agreement provides that the pledge over the mortgage receivables and related security will not be notified to the borrowers or other relevant parties, except if certain notification events occur, which include the notification events as detailed below and the giving of an enforcement notice, ie among others, non‐ timely payment of interest on the class A notes or the issuer’s insolvency or other material events affecting the issuer (the “pledge notification events”).

Set‐Off Risk Set‐off is allowed by Belgium law and case law between amounts owed by borrowers to the seller and vice versa. ING, acting as seller, will agree to indemnify the issuer if a borrower, insurance company or provider of additional collateral claims a right to set‐off against the issuer. The rights to payment of such indemnity will be pledged in favour of the secured parties.

In case of the insolvency of ING, borrowers will be able to invoke set‐off only for amounts closely connected, claims accrued prior to the bankruptcy, or loans with rebate payments.

Upon certain triggers (see below), borrowers will be notified of the transfer of their mortgage loan. Following such notification, they are no longer entitled to set‐off, except for loans with rebate payments (the risk of which is addressed in the below paragraph, Loans with Rebate Options).

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Commingling Risk ING, as guaranteed investment contract (GIC) provider and seller, will hold the seller collection account (cash is swept on a monthly basis into the issuer account) and the issuer collection account.

If the GIC provider is downgraded below ‘F1’ it will be replaced within 30 days.

Notification Events The sale and the pledge of the loans will be notified to the borrowers and any other relevant party (eg to insurance companies) if a notification event occurs. The latter includes the following, among others:

• a seller payment default is not remedied within 15 business days of receiving notice from the issuer or the security agent;

• the seller fails to fulfil or comply with any of its obligations and this is not remedied within 15 business days of receiving notice from the issuer or the security agent;

• any steps have been taken towards seller bankruptcy, insolvency proceedings or an ad hoc administrator appointment or entering into emergency regulations;

• a servicing termination occurred;

• ING’s rating falls below ‘F2’ or such rating is withdrawn.

Representations, Warranties and Eligibility Criteria The mortgage loan sale agreement contains representations and warranties given by the seller in relation to the pool of loans as of the closing date and on each purchase date during the revolving period. Following an irremediable breach of any of the representations, warranties or eligibility criteria, the seller will be required to repurchase the loan(s) in question.

The representations, warranties and eligibility criteria include the following:

• each loan, loan security and additional security exists and is a valid and binding obligation of the relevant borrower(s), or as the case may be, the relevant insurance company, and is enforceable in accordance with the terms of the relevant loan documents, provided, however, that the seller has made no investigations as to the existence of the insurance policies after the date of origination of each loan;

• each loan has been granted with respect to property located in Belgium; • no loan has been originated prior to 1 January 1995;

• each loan and relating mortgage complies in all material respects with the requirements of the Belgian mortgage credit act and implementing regulations;

• each loan has been granted by the seller for its own account; • each loan is granted under a credit facility; • at origination, each borrower was an individual resident in Belgium;

• the proceeds of each loan have been fully released and the seller has no further obligation to release further funds relating to the loan;

• the seller has not entered into any agreement, which would have the effect of subordinating the seller’s right of payment under any of the loans to any other indebtedness or other obligations of the borrower;

• on the cut‐off date, no loan is in arrears for more than one month;

• each loan, secured by the loan security and additional security, may be validly assigned to the issuer and pledged by the issuer in accordance with the pledge agreement;

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• the interest rate on each loan conformed to market practice at origination;

• each loan, except interest‐only mortgage loans, is repayable by way of monthly instalments, interest being payable in arrears (in some cases, with different payment frequencies as payments of principal);

• each loan is denominated exclusively in euros (including any loan historically denominated in Belgian frank);

• no loan has an initial maturity in excess of 30 years; • no interest‐only mortgage loan has an initial maturity less than 24 months; • in respect of each loan, at least one instalment has been received.

Revolving Period The issuer can purchase new mortgage loans up to February 2014, subject to the following conditions, among others:

• no notification event has occurred and is continuing;

• new loans meet the eligibility criteria;

• no new loan type can be added;

• the weighted average interest rate of the portfolio is between 3.0% and 5.5%;

• the weighted average remaining maturity of the loans shall not be less than 10 years and more than 25 years;

• the maximum weighted average debt‐to‐income (DTI) of the Portfolio is 38%;

• the weighted average mortgage to value is at maximum 90%; mortgage to value means, in respect of a loan, the ratio between the sum of all the mortgages and mandates securing a loan and the value of the property;

• no new loans can be purchased with a mortgage to value over 120%;

• the maximum weighted average loan‐to‐mortgage (LTM 1 ) is 125%;

• no more than 35% of the portfolio has an LTM higher than 100%;

• the sum of all pari passu loans (ie ranking pari passu with the securitised loans) and all other debts owed by the borrower to ING existing on the relevant purchase date does not exceed 7% of the portfolio;

• the maximum concentration per Belgian region is limited to 60% for Flanders, 45% for the Walloon region and 25% for the Brussels‐Capital region;

• no more than 6% of the loans purchased can be in arrears for less than 30 days;

• the issuer cannot purchase new mortgage loans for an amount greater than 10% of the then current portfolio amount per quarter;

• top 10 borrowers shall not represent more than 0.3% of the current portfolio amount, and

• no more than:

o 1.5% of the portfolio relates to interest‐only loans; o 4% of the portfolio relates to contractual loans; o 5% of the portfolio relates to loans granted to ING employees; o 15% of the portfolio relates to loans granted to self‐employed borrowers;

1 LTM means the ratio between: (i) the current balance of the loans of the borrower increased by the aggregate outstanding principal amount of all other loans secured by the same mortgage and all other loans and debts owed by the borrower to ING existing prior to or as of the cut‐off date; and (ii) the secured amount (including an amount for accessories equal to 10% of the secured principal amount) for which such mortgage has been registered in favour of the originator.

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o 2% of the portfolio relates to loans granted to unemployed borrowers; o 1.5% of the portfolio relates to loans initially granted to retired borrowers; o 1% of the portfolio relates to loans initially granted to student borrowers; o 9% of the portfolio relates to loans granted for construction;

o 8% of the portfolio relates to loans granted for the purpose of ‘Transformation’;

o 13% of the portfolio relates to loans granted for the purpose of ‘Purchase + Transformation’;

o 1% of the portfolio relates to property with mixed usage. Moreover, if one of the following stop revolving triggers is breached, the revolving period will stop and the notes will amortise sequentially:

• the average percentage of current defaulted loans (ie loans in arrears by more than 90 days) less foreclosed loans, on the relevant purchase date and the two months immediately preceding such payment date, does not exceed 1.5%;

• the cumulative losses in respect of the portfolio do not exceed a percentage equal to 0.025% times the outstanding mortgage balance on the relevant quarterly payment date, with the fraction increasing by 0.025% each quarter after closing.

Collateral ING provided Fitch with information on the initial portfolio, composed of 56,899 loans granted to 51,224 borrowers, for a total outstanding amount of EUR5.33bn. The main characteristics of the initial portfolio are detailed below:

Interest‐only Loans Interest‐only loans are loans for which the borrower only makes interest payments during the life of the loan and repays in full at maturity (such loans constitute 0.75% of the initial portfolio).

The total percentage of interest‐only loans is limited by the revolving period conditions (see section Revolving Period above).

Contractual Loans Contractual loans are loans where the borrower can make principal repayments on a monthly, quarterly, six‐monthly or annual basis. The interest is calculated on the outstanding balance of its debt. The amount of principal repayments, determined at the start of the loan, can, by upfront decision, be changed

Key Characteristics of the Initial Portfolio Outstanding principal balance (EUR) 5,330,415,230 Average borrower balance (EUR) 104,060 Number of borrowers 51,224 Weighted‐average seasoning (years) 2.88 Weighted‐average remaining maturity (years)

18.53

Weighted‐average coupon (%) 4.54 Weighted‐average DTI (%) 35.68 Weighted‐average current (loan + pari passu loans)/mortgage (%)

118.44

Weighted‐average MTV(%)(ie (mortgage + mandate)/property value

84.91

Employment type (%) Employed 79.79 Civil servant 5.46 Self‐employed 12.91 Retired 0.61 Student 0.14 Unemployed 0.99 ING employees (%) No 95.96 Yes 4.04 Loan amortisation type (%) Annuity 96.27 Contractual loans 2.98 Interest‐only loans 0.75 Loans purpose (%) Construction 6.53 Purchase 68.75 Purchase + transformation 10.76 Transformation 5.88 Refinance 7.19 Others 0.89 Property use (%) Mixed use 0.21 Private 99.79 Loans in arrears (%) No arrears 95.39 Less than 30 days arrears 4.61 Subsidised loans (%) No subsidised 97.15 Prêt jeunes 2.85 Loans with a rebate option (%) Loans without rebate option 97.87 Loans with rebate option 2.13

Source: ING/Fitch

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up to four times during the lifetime of the loan (such loans constitute 2.98% of the initial portfolio).

The total percentage of contractual loans is limited by the revolving period conditions (see section Revolving Period above).

Construction Loans All loans granted for construction (6.53% of the initial portfolio) or transformations (5.88% of the initial portfolio and 10.76% of the initial portfolio has been granted for ‘Purchase and Transformation’ purposes) have been fully disbursed prior to there transfer to the issuer.

The percentages of loans granted for these purposes are limited by the revolving period conditions (see section Revolving Period above).

Fixed‐ and Variable‐Rate Loans The mortgage loans bear interest on a capped floating‐rate basis (19.77% of the initial pool) or on a fixed‐rate basis (80.23% of the initial pool).

• floating‐rate loans provide an annual interest rate revision (three times) and a cap on the interest rate of 3% (ie the new interest rate must not increase by more than 3% in relation to the initial rate and no floor is applied to the interest rate decrease); or

• floating‐rate loans provide an initial period of five or 10 years with a fixed rate followed by a variable‐rate period with two quinquennial revisions of interest rates, and benefit from a cap on the interest rate of 5% or 2% (in the latter situation no floor is applied to the interest rate decrease).

Credit Facilities All mortgage receivables constitute term advances under a revolving credit facility (kredietopening/ouverture de crédit) (credit facility). The mortgages securing such mortgage receivables secure all advances made from time‐to‐time under such credit facility and, in many cases, all other amounts that the borrower owes or in future may owe to the seller. Upon transfer to the issuer, an advance shall rank in priority to any advances made under the facility after the date of the transfer. However, a transferred advance will have equal ranking with other advances that existed at the time of the transfer and which were secured by the same mortgage. However, those other advances and all other debts existing prior to the transfer date owed by the borrower to the seller which may be imputed on the same mortgage can only represent a maximum amount of 7% of the aggregate outstanding principal amount of mortgage receivables (see Revolving Period and the Credit Facility section in the Asset Analysis section for more details).

Arrears The initial portfolio contains 4.6% of loans in arrears for less than one month. Loans more than 30 days in arrears cannot be purchased by the issuer.

Employment Status Among the 79.79% employed borrowers, 4.04% are employed by ING Group’s entities. A limit on the portion of ING Group’s employees is in place (see section Revolving Period above).

Mandates The originator benefits from a “mortgage mandate” over a certain number of loans in the preliminary portfolio. This mandate is a particularity of the Belgian market (driven by the high cost of mortgage registration). It is not an actual security but it is an agreement between the borrower and a third party (the proxy, usually an employee of the lender or entity affiliated with the lender), in which the borrower gives the proxy the right to unilaterally create a mortgage for the benefit of the lender over a certain property as security.

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No benefit has been given to this security in the transaction analysis.

Loans with a Rebate Option 2.13% of the initial portfolio comprises loans with a rebate option. These loans benefit, under specific conditions, from temporary reductions of the interest rate, pursuant to which the borrower is entitled to receive repayment from the seller as regards the interest amount it has paid. The obligation to make such rebate payment (ristorno/ristourne) will not be transferred to the issuer. Nevertheless, if the seller does not make this repayment, the borrower will be allowed to set‐off the repayment amount with the payment due under the loans to the issuer.

No further loans with this feature can be bought during the revolving period.

Prêts Jeunes 2.85% of the initial portfolio comprises loans granted with the benefit of a guarantee extended by the Walloon region under the applicable housing promotion programme for building or acquiring houses by young persons (Prêts Jeunes).

These loans, in addition to the above guarantee, also benefit from a mortgage registered for the entire amount of the loan.

A limit on the portion of these loans has been set during the revolving period (see Revolving Period section).

Asset Analysis From the closing date until the end of the revolving period, unless a stop revolving trigger is breached, the principal available amount may be used entirely by the issuer to purchase new mortgage receivables under the conditions mentioned above. Fitch has carried out its analysis on a post‐revolving pro forma pool with the following characteristics derived from the limits imposed on the purchase of new mortgage receivables (ie maximum weighted average DTI allowed, etc):

Default Probability Generally, the two key determinants of default probability are the willingness and ability of a borrower to make the mortgage payments. Willingness to pay is usually measured by the OLTV ratio. Fitch assumed higher default probabilities for high‐OLTV loans and lower default probabilities for low‐OLTV loans. In this transaction, the

Key Characteristics of the Post‐ Revolving Portfolio Outstanding principal balance (EUR) 5,330,415,230 Average borrower balance (EUR) 104,060 Number of borrowers 51,224 Weighted‐average seasoning (years) 2.88 Weighted‐average remaining maturity (years)

18.53

Weighted‐average coupon (%) 3.0 Weighted‐average DTI (%) 38.0 Weighted‐average current (loan + pari passu loans)/mortgage (%)

125.0

Weighted‐average MTV(%)(ie (mortgage + mandate)/property value

90.0

Employment type (%) Employed 80.5 Civil servant 0 Self‐employed 15 Retired 1.5 Student 1.0 Unemployed 2.0 ING employees (%) No 95.0 Yes 5.0 Loan amortisation type (%) Annuity 94.5 Contractual loans 4.0 Interest‐only loans 1.5 Loans purpose (%) Construction 9.0 Purchase 63.8 Purchase + transformation 13.0 Transformation 8.0 Refinance 7.2 Others 0 Property use(%) Mixed use 1.0 Private 99.0 Loans in arrears (%) No arrears 87.5 Less than 30 days arrears 6.0 Between 30 and 60 days 3.0 Between 60 and 90 days 2.0 Defaulted loans 1.5 Subsidised loans (%) No subsidised 96.0 Prêt jeunes 4.0 Loans with a rebate option (%) Loans without rebate option 97.87 Loans with rebate option 2.13

Source: Fitch

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calculation of OLTV (used by Fitch to determine the willingness to pay of a borrower) is detailed in the section below.

Ability to pay is measured by the borrower’s net income in relation to the mortgage payment, ie the DTI ratio (see DTI section below).

LTV Original Loan‐to‐Value (OLTV) Due to the specificities of the Belgian market regarding the different types of security or other mechanisms (credit facilities, optional imputation of loans on mortgages and mortgage mandates), Fitch has adjusted the calculation of the OLTV to obtain figures compatible with its probability of default matrix. To determine such OLTV, the agency has taken into consideration the following elements:

1. the same borrower may have been granted several loans (due to credit facilities), whose purpose is not necessarily to purchase a property. In that case, the OLTV calculation does not reflect the willingness to pay of a borrower on his/her property;

2. in Belgium, mortgage registrations are very expensive, and borrowers often use a mortgage mandate in addition to a mortgage to back their loan;

3. in most cases, residential loans are fully backed by a security or an additional mechanism (composed of a mortgage and/or a mandate), which means that the residential loan amount used in Fitch’s analysis can be assumed to be equal to the security registered amount (or in case of mandates, potentially registered amounts) over such residential property.

Therefore, Fitch has approximated the calculation of OLTV by dividing the first available security amount of a borrower with the value of the property on which such securities rely. In this report, such calculation is called mortgage‐to‐value (MTV).

Fitch modelled the WA MTV revolving period limit at 90%.

Debt‐To‐Income Ratio (DTI) Fitch has modelled a WA DTI revolving period limit at 38% and distributed the loans between classes 3 to 5.

In addition to these two factors, other adjustments based on the Revolving Period section have been considered by Fitch, on a probability of default basis, to determine its post‐revolving pro forma portfolio:

Interest‐only Loans Interest‐only and contractual loans have been modelled so that they represent respectively 1.5% and 4.0% of the outstanding balance of the pool (the maximum according to the revolving period conditions).

Arrears Loans in arrears for less than 30 days have been increased to 6.0% on the total portfolio, in line with the eligibility criteria which sets a limit on new loans if the entire portfolio is performing as the new loans.

Loans in the 30 to 60 days and 60 to 90 days arrears bucket (respectively 3.0% and 2.0%) have also been modelled and represent the migration of the portfolio during the revolving period.

(Stresses applied are presented below in the Default Probability Stresses section.)

Defaulted Loans 1.5% of the loans have been modelled in default (ie with a default probability of 100%) as if the stop revolving trigger were breached, which would result in the end of the revolving period.

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Employment Status Fitch has distributed the borrower profiles for each debtor category at the maximum percentage allowed according to the revolving period limits.

Regarding ING Group’s employees, a hit on their probability of default has been applied to mitigate the risk of such employees losing their employment upon ING insolvency.

Default Probability Stresses The table below summarises the default probability increases applied on loans that carry a higher risk:

Default Probability Stresses Loan type (%) Self‐employed 20 Unemployed 25 Student 25 Retired 10 ING employee 25 Mixed‐use properties 20 One‐month arrears 25 Two‐months arrears 50 Three‐months arrears 75 Contractual loans 25 Interest‐only loans 20 Transformation loans 10

Source: Fitch

Recoveries Market Value Declines To estimate recoveries on the mortgage loans, Fitch examined house price movements in Belgium on a regional basis (Flanders/Brussels/Wallonia) between 1980 and 2006 (source: STADIM). House prices throughout Belgium have grown steadily in recent years and the last recession dates back to the early 1980s. The agency takes account of these trends and the inherent price volatility in its market value decline (MVD) analysis. Finally, high‐value (jumbo) properties face a risk of greater MVDs owing to a perceived lack of liquidity and, therefore, volatility in their market values. Fitch increased the MVDs for these loans by 15%‐30% based on the indexed value of the individual property (for further information, please refer to the report, “Revised MVD Assumptions for Belgian RMBS Transactions”, published 8 January 2007 and available at www.fitchratings.com).

MVDs have been increased by 10% when the loan purpose is construction or purchase and transformation (ie for respectively 9.0% and 13.0% of the post‐ revolving portfolio). This stress reflects the risk that, if the entire loan has been disbursed, the property might not be entirely finalised when the borrower defaults.

Coverage Ratio In Fitch’s recovery analysis, the mortgage coverage ratio conditions mentioned above have been modelled taking into account the limits set in the revolving period conditions on the LTM.

The mortgage coverage ratio is the ratio between the sum of all the mortgages securing a loan and the loans amounts (ie the inverse of the LTM, as defined in the Revolving Period section). Credit Facility As described above, existing loans on the purchase date are ‐ or may be if not yet imputed ‐ pari passu with the securitised ones. However, new loans granted and secured by the same mortgage are subordinated by law to the loans being

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securitised. Therefore, in case of foreclosure, the issuer will need to share the recovery proceeds with the loans that have been granted on or before the securitisation. Fitch has information as regards the initial pool and the maximum percentage following the revolving period. Therefore, the maximum percentage of pari passu loans has been modelled and recoveries have been allocated pro rata between the securitised loans and pari passu loans.

Mandates Fitch does not give credit to mortgage mandates under an ‘AAA’ scenario.

Recovery Rate To estimate the recovery rate, Fitch employed the following calculation: the lesser of: a) the minimum between i) the indexed property value net of foreclosure costs applied on the mortgage registration value (based on Fitch’s indexation methodology, whereby 50% credit is given for property price appreciation, and 100% credit is given for property price depreciation); and ii) the total amount of the mortgage reduced by foreclosure costs, MVD and jumbo factors; or b) the current balance of the loan, plus accrued interest relating to the mortgage receivable, based on the contractual rate for a period of 24 months, plus the principal balance of the mortgage receivable divided by the current balance of the loan.

It has also to be noted that, as mentioned in the Market Value Declines section above, MVDs and indexation applied in this transaction’s analysis are based on historical house price data from 1980 to 2006. Therefore, global house price growth that occurred in Belgium from 2006 until the beginning of 2008, and which would have slightly ameliorated recovery rates, has not been taken into account in Fitch’s analysis.

Moreover, the post‐revolving portfolio has been modelled with the minimum WA interest rate of 3%, according to the revolving period limits. The reduction of the initial WA interest rate of the portfolio from 4.54% to 3.00%, reflects the effect of the revolving period and incorporates the set‐off risk related to loans with a rebate option. Modelling a low interest rate results in lower recoveries on the defaulted loans’ accrued interest amount.

Default Model Summary Tables The table below shows the gross levels of the post‐revolving portfolio, as simulated by Fitch in its analysis. These levels are derived from the agency’s static default model before cash flow analysis.

Summary Table/Post‐Revolving Portfolio (%) WAFF a WARR b WA MVD c

AAA 20.67 56.78 42.84 AA 16.83 59.92 37.52 A 13.05 62.63 32.84 BBB 9.10 64.75 28.60 BB 5.35 66.75 24.37 a Weighted‐Average Foreclosure Frequency b Weighted‐Average Recovery Rate c Weighted‐Average Market Value Decline Source: Fitch

Cash Flow Analysis To evaluate the contribution of structural elements such as the liquidity line and other factors, Fitch modelled the cash flows from the mortgages based on the weighted‐average (WA) frequency of foreclosure and the WA recovery rate provided by the loan‐by‐loan collateral analysis.

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The cash flow analysis simulates the following elements (under several stress scenarios combining assumptions such as low or high prepayments, stable/increasing/decreasing interest rates and front‐loaded/evenly‐loaded/back‐ loaded default curves):

1. the cost of carrying defaulted loans as the difference between the performing balance of the mortgages and the notional note balance;

2. the variations in interest rates on the mortgage loans resulting from prepayments, reset or purchase of new mortgage receivables;

These variations impact the schedule payments by the issuer on the non‐ performing loans. There is no further negative impact on the cash flows as there is no excess spread in the transaction feature;

3. defaults and losses are tracked by the cash flow model, which determines, on a quarterly basis, whether they can be absorbed by available funds. In its cash flow modelling, Fitch assumes that realised losses will be registered on the PDL 24 months after a default occurs.

Fitch modelled that during the revolving period a stop revolving trigger has been breached; therefore, 1.5% of the loans have been modelled as being in default in the default model. As the revolving period can be longer than 24 months, which is Fitch’s assumption for realised losses, 30bp of additional credit enhancement have been added to covers losses occurred during the revolving period.

Administrator The administration function for this transaction will be carried out by ING Belgium N.V./S.A.

The transaction management team of ING Credit Portfolio Group was implemented in 2003 and manages all of ING Bank's transactions on its own assets. As of end November 2008, this team had EUR75bn of securitised assets under management, of which 85% were mortgages (comprising eight RMBS deals and one covered bond programme) and 15% were loans to small and medium‐sized enterprises (comprising three SME–backed deals).

The team is divided into two sub‐groups: portfolio/data analysis (three full‐time equivalents) and transaction administration (three full‐time equivalents). The first group is responsible for the preparation of the first pool, putting in place the information flows from the source systems to transaction management, and for making the replenishment and reporting templates. The second group is responsible for the set up of the transaction agreements in ING's front‐office and accounting systems, and for the day‐to‐day management of the transactions (including the replenishment, reporting and payment instructions) using the templates prepared by the first group. Both groups are headed by experienced managers who have over eight years of experience in transaction management or related areas.

Origination and Servicing ING group is one of the world’s leading financial institutions, rated ‘AA‐’ Outlook Negative/’F1+’. It comprises two main subsidiaries: ING Bank, which contains most of the banking business, and ING Verzekeringen, which contains most of the insurance activities. ING Belgium SA/NV (the originator) is part of ING Bank.

ING Belgium is the fourth‐largest Belgian bank, with a 13% market share of savings deposits on a consolidated basis (as of December 2007). It is a universal bank providing a full range of products to both retail and commercial clients. ING’s outstanding amount of mortgage loans totalled approximately EUR14bn at end‐2007 (which represents a market share of approximately 12%). Its strategy for the mortgage loans sector is to focus on its current clients and their relatives.

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ING Belgium became a wholly‐owned subsidiary of ING Group in 1998. Before 2003, ING Belgium was still called Banque Bruxelles Lambert (BBL) which was the result of a former merger of Banque de Bruxelles and Banque Lambert in June 1975.

Origination Process Mortgage loans are only originated by ING Belgium branches. The latter can be either franchised (234 branches) or statutory (550 branches), nevertheless in both cases the underwriting criteria are the same. 70% of mortgage loan production in 2007 was originated through statutory branches. There is no origination via Internet channels, call centres or brokers.

Before July 2006, there was no internal risk scoring per client and a list of conditions had to be met to receive approval at the agency level. If these conditions were not met, the application was transferred to a specialised analyst.

Since July 2006, risk classes for clients have been established (information is updated on a global client basis) and an automatic approval system has been implemented. The risk manager proposes the ‘underwriting’ and ‘limits’ criteria to be applied by the system to the product and sales department for validation. System parameters are updated once or twice per year.

Automatic approval is possible for applications up to EUR500,000 which have a good risk class and are within specific decision rules. This system is the same across all ING branches, ie both statutory and franchised.

The system can give one of the following feedbacks:

• Green: automatic approval but the loan contract shall be sent by the back‐up service after a check of all documents;

• Orange: the decision cannot be automatically taken and the file needs to be examined manually. Some limited approval power has been given to ING’s statutory braches. If the loan amount is above the branch manager approval limit, the application is transferred to the Support and Decision Mortgages (SDM) team which is composed of 30 persons located in Namur (Wallonia) and in Gent (Flanders); this has an approval limit up to EUR1m. For applications above this amount, but below EUR2.5m, the file is transferred to the Regional Risk Manager (RRM). Above this limit, the application is transferred to the risk department located in Brussels;

• Red: the application is refused.

The feedback given by the system is based on the following key parameters: internal risk class; level of debt to available Income; level of LTV; and credit amount and security (ie registered mortgage, mandate or promise). To determine these parameters, information is required by the system which includes the borrower’s existing debts (there is also an automatic National Bank of Belgium (NBB) check of the borrower’s current financial obligations and any negative credit history; the latter is not a reason for a systematic refusal), additional internal negative information, their income (eg pay slip or income tax form), deed or selling contract, and permission or certificate for construction.

An expert valuation report is always required for loans above EUR300.000. SDM has established a list of valuation experts with the approval of the Regional Risk Manager. For applications below EUR300.000, a ‘replacing value’ can be accepted for the property valuation (such as the price on the selling contract or an existing valuation report). According to the situation, the decision maker may require a valuation by an expert.

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As of end‐2008, approximately 48% of applications were automatically approved and 2% were automatically refused. Overall, approximately 8% of applications were refused either automatically or manually.

The originator’s objective is to increase the automation of its underwriting process and the standardisation of its products.

The on‐going management of originated loans is done automatically, via direct debit for all loans on the first day of each month. If the money is not on the borrower’s account, the demand for debit is repeated several times.

Servicing The first stage of follow‐up of arrears is done automatically and letters are sent to the borrower after the first and the second unpaid instalment. If the loan is still in arrears it is transferred to the ING Call Centre ‐ called ING Contract Centre Bad Debt Recovery (ICC BDR) ‐ and the file is transferred to the RER system. The call centre takes care of all unpaid amounts for all types of products and specific employees (17 persons) are dedicated to the mortgage loans.

The latter have specific training ‐ which includes mortgage product knowledge covering mortgage law and fraud ‐ and they can agree on a repayment plan for the unpaid amounts. In case of unsuccessful regularization, the loan can be denounced or delayed up to one year under specific circumstances.

Following this process, loans are transferred to the Recovery team, which comprises 40 staff dedicated to the retail bank. The foreclosure process can be initiated as soon as the mortgage is denounced. ING has a title to execute the mortgage, but due to regulatory requirements, the liquidation takes on average 15 months.

There are two paths to foreclosure:

• voluntary sale: the borrower offers the property for sale with the help of an estate agent and in close coordination with the recovery department. This type of foreclosure tends to be more beneficial to the property valuation. The borrower can continue their efforts to find a buyer even during the legal proceedings;

• public auction: the property is offered for sale at a public auction. This alternative is considered as a last resort, after all alternatives have failed.

If a residual debt remains after the public or private sale, the borrower is liable for that residual debt. The claim is then sold to Fiducré, an ING collection agency, in order to try to collect the residual debt.

Performance Analytics Fitch will monitor the transaction regularly and as warranted by events. Its structured finance performance analytics team ensures that the assigned ratings remain, in the agency’s view, an appropriate reflection of the issued notes’ credit risk.

Details of the transaction's performance are available to subscribers at www.fitchresearch.com. Further information on this service is available at www.fitchratings.com.

Please call the Fitch analysts listed on the first page of this report for any queries regarding the initial analysis or the ongoing performance

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Appendix 1: Rating Methodology Rating Methodology To determine appropriate levels of credit enhancement, Fitch analyses the collateral for Belgian residential transactions using a loan‐by‐loan mortgage default model. The agency updated its Belgian default model in May 2005. This appendix gives an overview of the determinants of the default model. The model subjects the mortgage loans to stresses resulting from its assessment of historical house price movements and mortgage defaults in Belgium. Fitch believes a borrower’s LTV, reflecting the size of their down‐payment and their willingness to pay, and a borrower’s DTI or income multiple, reflecting their ability to pay, to be the key determinants of default probability in Belgium.

Default Probability Generally, the two key determinants of default probability are the borrower’s willingness and ability to make their mortgage payments. The willingness of a borrower to pay is usually measured by the LTV. Fitch’s model assumes higher default probabilities for high‐LTV loans and lower default probabilities for low‐LTV loans. The main reason for this is that, in a severe negative equity situation, borrowers in financial distress but with equity in their homes (low‐LTV loans) have an incentive to sell and maintain/protect their equity, eliminating the need for the lender to repossess the property.

The ability to pay is usually measured by the borrower’s net income in relation to the mortgage payment. Base default probabilities are determined using a matrix that considers each loan’s affordability factor and LTV. The matrix classifies affordability into five categories, the lowest of which (class 1), encompasses loans with DTIs of less than 20% and the highest of which (5) encompasses all loans with DTIs exceeding 50%.

Fitch’s ‘AAA’ Default Probabilities a

DTI LTV (%) Class 1 Class 2 Class 3 Class 4 Class 5 < 40.00 5.00 5.50 6.00 7.08 7.60 40.00–49.99 5.50 6.00 6.50 7.55 8.05 50.00–59.99 6.00 6.50 7.25 8.40 8.95 60.00–64.99 6.50 7.00 7.92 9.07 9.66 65.00–69.99 6.91 7.50 8.72 10.07 10.88 70.00–74.99 7.68 8.39 9.80 11.35 12.29 75.00–79.99 8.44 9.42 11.00 12.84 13.70 80.00–84.99 9.59 10.89 13.15 15.21 16.21 85.00–89.99 11.21 12.95 15.00 17.48 19.16 90.00–93.99 13.74 15.45 17.76 20.26 22.61 94.00–97.99 16.89 18.32 21.07 23.64 26.25 98.00–99.99 20.05 21.86 24.94 27.53 31.20 > = 100.00 24.06 26.24 29.93 33.15 37.46 a 10‐year cumulative probabilities subject to the adjustments described below Source: Fitch

Fitch DTI Classes (%) Class 1 < 20.00 Class 2 20.00–29.99 Class 3 30.00–39.99 Class 4 40.00–49.99 Class 5 ≥ 50.00

Source: Fitch

Adjustments Fitch adjusts the base default rates on a loan‐by‐loan basis to account for the individual loan characteristics of the collateral across all rating levels.

Repayment Type Interest‐Only: Fitch generally increases the default assumptions for interest‐only mortgages ‐ whereby the mortgage is secured solely by the property value and principal is repaid by the borrower in one lump sum upon loan maturity ‐ to take into account the potential payment shock to the borrower and the reliance on the borrower’s equity in the property.

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Loan Purpose Fitch assumes that a financially distressed borrower is more likely to default on a second home than a primary residence, and even more so on an investment property. Accordingly, base default rates are increased by 5%‐20%.

Borrower Profile Fitch increases default probability on loans to self‐employed borrowers by 20% to account for their lack of a fixed annual salary.

Arrears Status When rating portfolios combining current and arrears mortgages, Fitch increases base default rates for mortgages in arrears by up to 90 days by 25%‐75%, and those over 91 days in arrears (non‐performing status) by 100%.

Underwriting Quality Fitch’s review and analysis of the origination process determines whether it decreases default rates by up to 25% or increases them by 0%‐200%.

Please refer to the Default Probability Stresses table on page 18 to see the other adjustments.

Recoveries To estimate recovery rates on mortgage loans in Belgium, Fitch examined home price movements in three Belgian regions between 1980 and 2004 (source: Stadim). Worst‐case MVDs were estimated and were then generated for each rating level and by region. Generally, Fitch increased the MVD to reflect the increase in home price movements over recent years.

As in its other European mortgage default models, Fitch increased MVDs for properties worth more than EUR250,000 by 15%‐30% depending on the region. Higher‐value properties tend to have larger MVDs owing to the smaller marketplace and the less precise pricing information for such properties (given the less active market).

Fitch’s model gives full credit for property price declines and 50% credit for property price appreciation. The agency calculates recoveries by reducing the indexed property valuation by the MVD, repossession costs and the costs to the servicer of carrying the loan from delinquency through to default.

Fitch assumes that repossession costs represent EUR5,000.

Fitch’s MVDs for Belgium – Houses Region (%) AAA AA A BBB BB Brussels 45 38 33 28 23 Flanders 42 37 32 28 23 Wallonia 43 38 33 28 23

Source: Fitch

Fitch’s MVDs for Belgium – Apartments Region (%) AAA AA A BBB BB Brussels 45 40 35 31 27 Flanders 37 32 29 25 21 Wallonia 40 35 30 26 22

Source: Fitch

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Appendix 2: Transaction Summary

Belgian Lion N.V./ S.A ‐ Compartment Belgian Lion RMBS I Belgium/RMBS Capital Structure Class Rating Size (%) Size (EURm) CE (%) Interest rate PMT freq Maturity Margin (bps) ISIN A AAA 90.35 4,816.00 9.65 3M Euribor Quarterly Nov 2045 140 BE0002383553 B NR 9.65 514.50 0.0 3M Euribor Quarterly Nov 2045 300 BE0002384569

Size (%) Size (EURm) Liquidity 5.0 266.53

The rated class has a Stable Outlook Source: Fitch and Transaction documents

Key Information Parties

Closing date 12 January 2009 Seller/originator ING Belgium N.V./S.A. Country of assets Belgium Servicer ING Belgium N.V./S.A. Country of SPV Belgium Arranger and manager ING Belgium N.V./S.A. ISIN BE0002383553

BE0002384569 Paying agent ING Belgium N.V./S.A.

Issuance date 12 January 2009 GIC provider ING Belgium N.V./S.A. Structure True sale, pass‐through Swap counterparty ING Belgium N.V./S.A.

Liquidity facility provider ING Belgium N.V./S.A. Listing Euronext Brussels Seller collection account bank ING Belgium N.V./S.A. Analysts Helene Weintraub Spira +33 1 44 29 91 20 Henri de Mont‐Serrat +33 1 44 29 91 39

Source: Fitch and Transaction documents

Others (Summary) Short‐term rating triggers (minimum) Swap counterparty ‘A’/‘F1’ Liquidity facility provider ‘F1’ Transaction account bank ‘F1’

Credit enhancement At closing, 9.65% subordination by a subordinated class of notes.

Credit committee highlights • Belgian Lion N.V./S.A. Compartment Belgian Lion RMBS I is the

first public RMBS transaction originated by ING Belgium N.V. /S.A., part of the ING Group.

• This transaction structure does not benefit from any excess spread or a reserve fund. At closing, credit enhancement for the class A notes was provided by a subordinated class of notes.

• During the five year revolving period, the issuer can purchase new mortgage loans subject to certain conditions.

• ING Belgium N.V./S.A. is the provider of a 5% liquidity facility. The facility is available to meet interest shortfalls on the class A notes.

• The risk of a mismatch between interest received from the portfolio and interest payable on the notes is mitigated by an interest rate swap agreement between the SPV and ING Belgium N.V./S.A..

Source: Transaction documents, Fitch

Fitch Default Model Output for Post‐Revolving Portfolio Rating level (%) AAA AA A BBB WAFF 20.67 16.83 13.05 9.10 WARR 56.78 59.92 62.63 64.75 WAMVD 42.84 37.52 32.84 28.60

Source: Fitch

Transaction Diagram

Source: Fitch

Interest Rate Swap

Counterparty

ING Belgium

Liquidity Facility Provider

GIC Provider

ING Belgium

Security Agent

Stichting Security Agent Belgian Lion

ING Belgium as Seller and

Servicer

Belgian Lion N.V./S.A

Compartment Belgian Lion

RMBS I

Class A

Class B

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Copyright © 2009 by Fitch, Inc., Fitch Ratings Ltd. and its subsidiaries. One State Street Plaza, NY, NY 10004.Telephone: 1‐800‐753‐4824, (212) 908‐0500. Fax: (212) 480‐4435. Reproduction or retransmission in whole or in part is prohibited except by permission. All rights reserved. All of the information contained herein is based on information obtained from issuers, other obligors, underwriters, and other sources which Fitch believes to be reliable. Fitch does not audit or verify the truth or accuracy of any such information. As a result, the information in this report is provided "as is" without any representation or warranty of any kind. A Fitch rating is an opinion as to the creditworthiness of a security. The rating does not address the risk of loss due to risks other than credit risk, unless such risk is specifically mentioned. Fitch is not engaged in the offer or sale of any security. A report providing a Fitch rating is neither a prospectus nor a substitute for the information assembled, verified and presented to investors by the issuer and its agents in connection with the sale of the securities. Ratings may be changed, suspended, or withdrawn at anytime for any reason in the sole discretion of Fitch. Fitch does not provide investment advice of any sort. Ratings are not a recommendation to buy, sell, or hold any security. Ratings do not comment on the adequacy of market price, the suitability of any security for a particular investor, or the tax‐exempt nature or taxability of payments made in respect to any security. Fitch receives fees from issuers, insurers, guarantors, other obligors, and underwriters for rating securities. Such fees generally vary from US$1,000 to US$750,000 (or the applicable currency equivalent) per issue. In certain cases, Fitch will rate all or a number of issues issued by a particular issuer, or insured or guaranteed by a particular insurer or guarantor, for a single annual fee. Such fees are expected to vary from US$10,000 to US$1,500,000 (or the applicable currency equivalent). The assignment, publication, or dissemination of a rating by Fitch shall not constitute a consent by Fitch to use its name as an expert in connection with any registration statement filed under the United States securities laws, the Financial Services and Markets Act of 2000 of Great Britain, or the securities laws of any particular jurisdiction. Due to the relative efficiency of electronic publishing and distribution, Fitch research may be available to electronic subscribers up to three days earlier than to print subscribers.

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