2019 Annual Report On Nationally Recognized Statistical .
Annual Report on Nationally RecognizedStatistical Rating OrganizationsAs Required by Section 6of the Credit Rating Agency Reform Act of 2006This is a report of the Staff of the U.S. Securities and Exchange Commission.The Commission has expressed no view regarding the analysis, findings, or conclusionscontained herein.January 2020
TABLE OF CONTENTSI.INTRODUCTION. 1II.STATUS OF REGISTRANTS AND APPLICANTS . 2III. ACTIVITIES RELATING TO NRSROs . 4A.Activities . 4B.Commission Orders and Releases and Staff Publications . 6IV. COMPETITION . 8A.B.C.V.Select NRSRO Statistics . 81.NRSRO Credit Ratings Outstanding . 82.NRSRO Analytical Staffing Levels . 143.NRSRO Revenue . 15Recent Developments in the State of Competition Among NRSROs . 171.Market Share Observations in the Asset-Backed Securities RatingCategory . 17(a) CMBS .18(b) ABS/MBS/CLO .212.Other Asset-Backed Securities Market Share Observations . 22Barriers to Entry. 24TRANSPARENCY . 26VI. CONFLICTS OF INTEREST . 28VII. CONCLUSION . 29i
TABLE OF CHARTSChart 1: Number of Outstanding Credit Ratings as of December 31, 2018 by RatingCategory .10Chart 2: Percentage by Rating Category of Each NRSRO’s Outstanding Credit Ratingsof the Total Outstanding Credit Ratings of all NRSROs, as of December 31, 2018 .11Chart 3: Breakdown of Ratings Reported Outstanding on December 31, 2018 .12Chart 4: Breakdown of Non-Government Securities Ratings Reported Outstanding onDecember 31, 2018 .13Chart 5: NRSRO Credit Analysts and Credit Analyst Supervisors .14Chart 6: NRSRO Revenue Information: Fiscal Year Percentage of Total ReportedNRSRO Revenue .15Chart 7: Rating Agency Market Share for Total Non-Agency U.S. CMBS Issued in2017, 2018, and First Half of 2019 .19Chart 8: Rating Agency Market Share for U.S. Conduit CMBS Issued in 2017, 2018, andFirst Half of 2019 .19Chart 9: Rating Agency Market Share for U.S. Single Borrower CMBS Issued in 2017,2018, and First Half of 2019 .19Chart 10: Rating Agency Market Share for Agency CMBS Issued in 2017, 2018, andFirst Half of 2019 .20Chart 11: Rating Agency Market Shares for U.S. ABS Issued in 2017, 2018, and FirstHalf of 2019 .21Chart 12: Rating Agency Market Shares for U.S. MBS Issued in 2017, 2018, and FirstHalf of 2019 .21Chart 13: Rating Agency Market Shares for U.S. CLO Issued in First Half of 2017,2018, and First Half of 2019 .22ii
ANNUAL REPORT ON NATIONALLY RECOGNIZEDSTATISTICAL RATING ORGANIZATIONSAs Required by Section 6 of the Credit Rating AgencyReform Act of 2006I.INTRODUCTIONThe staff (the “Staff”) of the U.S. Securities and Exchange Commission (the“Commission” or “SEC”) is providing this report (“Report”) regarding nationally recognizedstatistical rating organizations (“NRSROs”) pursuant to Section 6 of the Credit Rating AgencyReform Act of 2006 (“Rating Agency Act”). 1 This Report reflects solely the Staff’s views.Section 6 of the Rating Agency Act requires the Commission to submit an annual report(“Annual Report”) to the Committee on Banking, Housing, and Urban Affairs of the U.S. Senateand the Committee on Financial Services of the U.S. House of Representatives (“CongressionalCommittees”) that, with respect to the year to which the Annual Report relates: identifies applicants for registration as NRSROs under Section 15E of the SecuritiesExchange Act of 1934, as amended (the “Exchange Act”); 2 specifies the number of, and actions taken on, such applications; and specifies the views of the Commission on the state of competition, transparency, andconflicts of interest among NRSROs.This Report generally focuses on the period from June 26, 2018 to June 25, 2019 (the“Report Period”). In addition to addressing the items specified in Section 6 of the RatingAgency Act, this Report provides an overview of certain Commission and Staff activities relatingto NRSROs.Information regarding the topics covered in this Report with respect to prior periods canbe found on the Office of Credit Ratings (“OCR” or the “Office”) page of the Commission’swebsite. 31Pub. L. No. 109-291, 120 Stat. 1327 (Sept. 29, 2006). The Rating Agency Act, among other things, addedSection 15E to the Securities Exchange Act of 1934 to establish self-executing requirements on NRSROsand provide the Commission with the authority to implement a registration and oversight program forNRSROs. In June 2007, the Commission approved rules implementing such a program. See Oversight ofCredit Rating Agencies Registered as Nationally Recognized Statistical Rating Organizations, Release No.34-55857, 72 FR 33564 (Jun. 18, 2007), available at 2Unless otherwise noted, all references to specific statutory sections and rules in this Report are to sectionsin the Exchange Act and related rules.3Prior Annual Reports can be found under “Annual Reports to Congress” in the “Reports and Studies”section of the OCR webpage, available at https://www.sec.gov/ocr.1
II.STATUS OF REGISTRANTS AND APPLICANTSSection 3(a)(62) defines a “nationally recognized statistical rating organization” as acredit rating agency that is registered under Section 15E and issues credit ratings certified byqualified institutional buyers, in accordance with Section 15E(a)(1)(B)(ix), with respect to:(i)(ii)(iii)(iv)(v)(vi)financial institutions, brokers, or dealers;insurance companies;corporate issuers;issuers of asset-backed securities (as that term is defined in 17 CFR 229.1101(c));issuers of government securities, municipal securities, or securities issued by aforeign government; ora combination of one or more categories of obligors described in any of clauses(i) through (v) above.As of the date of this Report, there are nine credit rating agencies registered as NRSROs. 4The NRSROs, categories of credit ratings described in clauses (i) through (v) of Section3(a)(62)(A) in which they are registered, and locations of their principal offices, as of the date ofthis Report, are listed below: 5NRSROCategories of Credit RatingsPrincipal OfficeA.M. Best Rating Services, Inc.(“A.M. Best”)(ii), (iii), and (iv)U.S.DBRS, Inc.(“DBRS”)(i) through (v)U.S.Egan-Jones Ratings Company(“EJR”)(i) through (iii)U.S.Fitch Ratings, Inc.(“Fitch”)(i) through (v)U.S.HR Ratings de México, S.A. de C.V.(“HR Ratings”)(i), (iii), and (v)MexicoJapan Credit Rating Agency, Ltd.(“JCR”)(i), (ii), (iii), and (v)JapanKroll Bond Rating Agency, Inc.(“KBRA”)(i) through (v)U.S.Moody’s Investors Service, Inc.(“Moody’s”)(i) through (v)U.S.S&P Global Ratings(“S&P”)(i) through (v)U.S.During the Report Period, Morningstar Credit Ratings, LLC (“Morningstar”) was alsoregistered as an NRSRO in the categories of credit ratings described in clauses (i), (iii), and (iv)of Section 3(a)(62)(A). On July 2, 2019, Morningstar, Inc., the parent of Morningstar,completed an acquisition of DBRS. On November 15, 2019, Morningstar furnished a notice of4Section 15E(a) sets out registration procedures for a credit rating agency to voluntarily apply to beregistered with the Commission as an NRSRO.5See the current Form NRSRO on each NRSRO’s website for any updates to this information.2
withdrawal from registration to the Commission (which became effective on December 30,2019), and DBRS filed an update to Form NRSRO to add Morningstar as a credit rating affiliate.Given that Morningstar and DBRS operated separately during the Report Period and thatMorningstar was separately registered as an NRSRO until December 30, 2019, this Reportincludes information reported by and about Morningstar and DBRS, individually.For purposes of this Report only, we refer to Fitch, Moody’s, and S&P as larger NRSROsand the other NRSROs (A.M. Best, DBRS, EJR, HR Ratings, JCR, KBRA, and Morningstar) assmaller NRSROs.Applications for initial registration and for registration by current NRSROs in additionalrating categories are filed on Form NRSRO (“Form NRSRO”). 6 In addition, Section 15E(b)requires NRSROs to promptly amend Form NRSRO if any information or document providedtherein becomes materially inaccurate. This section also requires NRSROs to annually amendForm NRSRO to update ratings count and performance information, certify the continuingaccuracy of the information and documents provided therein, and list any material change theretoduring the previous calendar year. OCR Staff review such amendments to Forms NRSRO inlight of the requirements of Section 15E(b), Rule 17g-1, and the instructions to Form NRSRO.No complete applications for initial registration as an NRSRO or for registration bycurrent NRSROs in additional rating categories were received during the Report Period.As discussed in the December 2018 Annual Report, the Commission issued orders inconnection with an application filed by EJR, on April 10, 2018, to re-register in the asset-backedsecurities and government securities credit ratings classes. 7 Specifically, on July 9, 2018, theCommission issued an order instituting proceedings pursuant to Section 15E(a)(2)(A)(ii) todetermine whether EJR’s application should be granted or denied. 8 On November 2, 2018, the6See Section 15E(a) and Rule 17g-1. Rule 17g-1 requires an applicant/NRSRO to use Form NRSRO for thefollowing, as applicable: an initial application to be registered as an NRSRO;an application to register for an additional class of credit ratings;an application supplement;an update of registration pursuant to Section 15E(b)(1);an annual certification pursuant to Section 15E(b)(2); anda withdrawal of registration pursuant to Section 15E(e).See also Form NRSRO, available at https://www.sec.gov/about/forms/formnrsro.pdf.7EJR had previously been registered in such ratings classes. See Order Granting Registration of Egan-JonesRating Company to Add Two Additional Classes of Credit Ratings, Release No. 34-59056 (Dec. 4, 2008),available at https://www.sec.gov/rules/other/2008/34-59056.pdf. On January 22, 2013, EJR and its founderSean Egan consented to a Commission order under which, among other things, EJR agreed to be barredfrom rating asset-backed and government securities issuers as an NRSRO, with the right to re-apply forregistration in these classes after 18 months from the date of the order. See In the Matter of Egan-JonesRatings Company and Sean Egan, Release No. 34-68703 (Jan. 22, 2013), available 03.pdf.8See Order Instituting Administrative Proceedings Pursuant to Section 15E(a)(2)(A)(ii) of the SecuritiesExchange Act of 1934 and Notice of Hearing, Release No. 34-83610 (July 9, 2018), available 10.pdf.3
Commission issued an order dismissing the proceedings in response to EJR’s motion to dismissthe proceedings following EJR’s voluntary withdrawal of its application. 9III.ACTIVITIES RELATING TO NRSROsA.ActivitiesThe Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) 10mandated the creation of OCR. OCR is responsible for the oversight of credit rating agenciesregistered with the Commission as NRSROs. OCR’s Staff includes professionals with expertisein a variety of areas that relate to its regulatory mission, such as corporate, municipal, andstructured debt finance. 11OCR’s responsibilities – as mandated by the Dodd-Frank Act – include, among otherthings, conducting an examination of each NRSRO at least annually in eight specified reviewareas. 12 Information regarding the examinations is included in OCR’s annual examinationreports. 13OCR also monitors trends and developments affecting the credit rating industry. Forexample, OCR Staff may meet with NRSROs to discuss rating and industry developments andwith the boards of directors of NRSROs to discuss, among other things, compliance andoversight matters. OCR Staff also may meet with a variety of other market participants,including investors, issuers, regulators, and industry organizations, to discuss matters relevant tothe credit rating industry.During the Report Period, OCR Staff continued to participate in meetings that involvedrating agency regulators globally, including those of the supervisory colleges that were formedfor the largest internationally-active credit rating agencies. The supervisory colleges wereformed to enhance communication among credit rating agency regulators globally with respect toexaminations of the relevant credit rating agencies. 14 During the Report Period, each collegeheld an in-person meeting and conducted quarterly calls. OCR Staff also conducted additionaldiscussions with international regulators, as appropriate.9See Order Dismissing Proceedings, Release No. 34-84530 (Nov. 2, 2018), available 84530.pdf.10See Pub. L. No. 111-203, 124 Stat. 1376 (2010).11See Section 15E(p)(2) for a description of OCR staffing requirements.12See Section 15E(p)(3) for a description of the scope of the required examinations.13The examination reports can be found under “Summary Examination Reports” in the “Reports and Studies”section of the OCR webpage, available at https://www.sec.gov/ocr.14See Supervisory Colleges for Credit Rating Agencies, Final Report (July 2013), available D416.pdf. The SEC serves as chair of the colleges forS&P and Moody’s, and OCR Staff represents the SEC in this regard. The European Securities and MarketsAuthority serves as chair of the college for Fitch.4
During the Report Period, the Fixed Income Market Structure Advisory Committee(“FIMSAC”) 15 established a Credit Ratings Subcommittee to consider the role of credit ratingsissued by NRSROs in the corporate bond and municipal securities markets. 16 At the FIMSACmeeting on July 29, 2019, the FIMSAC considered issues relating to NRSRO competition andNRSRO compensation models. 17 At the FIMSAC meeting on November 4, 2019, the FIMSACagain considered the issue of NRSRO compensation models. 18In addition, the SEC’s Investor Advisory Committee (“IAC”) 19 met on July 25, 2019 todiscuss the SEC’s approach to regulation in areas with limited competition, including the creditrating agency industry. 20 The IAC met on September 19, 2019 to discuss increased leverage andrelated SEC regulatory implications, including the role of NRSROs in the leveraged loan andCLO markets. 21 At the IAC meeting on November 7, 2019, 22 Chairman Jay Clayton suggestedfuture topics of focus for the committee, including questions related to credit rating agencies. 2315In November 2017, the Commission formed the FIMSAC to provide the Commission with diverseperspectives on the structure and operations of the U.S. fixed income markets, as well as advice andrecommendations on matters related to fixed income market structure. The FIMSAC’s current charter isavailable at: y-committee/fimsac-charter-nov-2019.pdf.16Topics that may be considered by the Credit Ratings Subcommittee include, but are not limited to, (1) theuse of credit ratings by various market participants and the implications of ratings changes for these marketparticipants, (2) the costs and benefits of the current model for credit rating issuance, (3) the U.S.regulatory regime for credit rating agencies registered as NRSROs, and (4) issuances of unsolicited creditratings and the publication of commentaries. See committee-subcommittees.htm.17See webcast of Fixed Income Market Structure Advisory Committee Meeting, SEC (July 29, 2019), available .shtml?document id fimsac072919.18See webcast of Fixed Income Market Structure Advisory Committee Meeting, SEC (Nov. 4, 2019),available at html?document id fimsac110419.19Section 911 of the Dodd-Frank Act established the Investor Advisory Committee to advise the Commissionon regulatory priorities, the regulation of securities products, trading strategies, fee structures, theeffectiveness of disclosure, and on initiatives to protect investor interests and to promote investorconfidence and the integrity of the securities marketplace. The Dodd-Frank Act authorizes the Committeeto submit findings and recommendations for review and consideration by the Commission. -committee.shtml.20See webcast of Investor Advisory Committee Meeting, SEC (July 25, 2019), available .shtml?document id iac072519.21See webcast of Investor Advisory Committee Meeting, SEC (Sept. 19, 2019), available .shtml?document id iac091919.22See webcast of Investor Advisory Committee Meeting, SEC (Nov. 7, 2019) available .shtml?document id iac110719.23See Chairman Jay Clayton, Remarks to the SEC Investor Advisory Committee (Nov. 7, 2019), available n-remarks-investor-advisory-committee-110719 (notinginterest in issues such as reliance by retail investors on credit rating agencies, whether credit rating agenciesare appropriately disclosing, monitoring and managing their conflicts, whether investors are harmed bycompensation models of credit rating agencies, and whether there are alternative payment models thatwould better align the interests of rating agencies with those of investors).5
B.Commission Orders and Releases and Staff PublicationsThe Commission and the Staff, as applicable, issued the following orders, releases, andpublications relating to NRSROs or credit ratings in general from the start of the Report Periodto December 31, 2019: Amendments to Rules for Nationally Recognized Statistical Rating Organizations,Release No. 34-86590 (Aug. 7, 2019), 84 FR 40247 (Aug. 14, 2019). 24 The Commissionadopted an amendment to Rule 17g-5(a)(3) that provides for an exemption from the rulewith respect to credit ratings for certain structured finance products where the issuer is anon-U.S. person and the NRSRO has a reasonable basis to conclude that the structuredfinance product will be offered and sold exclusively outside the United States. In theadopting release, the Commission directed the Staff to further evaluate the effectivenessof Rule 17g-5(a)(3) with respect to ratings of structured finance products that are noteligible for relief under the exemption. The Commission also adopted conformingamendments to similar exemptions in Rule 17g-7(a) and Rule 15Ga-2. 2018 Summary Report of Commission Staff’s Examinations of Each NationallyRecognized Statistical Rating Organization, dated December 2018, as required underSection 15E(p)(3)(C). 25 The report summarizes essential findings of the examinationsconducted by Staff under Section 15E(p)(3)(C), generally focusing on the period fromJanuary 1, 2017 through December 31, 2017. Annual Report on Nationally Recognized Statistical Rating Organizations, datedDecember 2018, as required by Section 6 of the Rating Agency Act. 26 The AnnualReport addresses the matters described in the first paragraph under Section I. of thisReport, generally covering the period from June 26, 2017 to June 25, 2018. Order Dismissing Proceedings, Release No. 34-84530 (Nov. 2, 2018). 27 TheCommission issued an order dismissing the proceedings to determine whether EJR’sapplication for registration in the asset-backed securities and government securities creditratings classes should be granted or denied. The Commission issued the order inresponse to EJR’s motion to dismiss the proceedings following EJR’s voluntarywithdrawal of its application.24Available at 25Available at 8 0.pdf.26Available at sros.pdf.27Available at 530.pdf.6
Proposed Amendments to Rules for Nationally Recognized Statistical RatingOrganizations, Release No. 34-84289 (Sept. 26, 2018), 83 FR 50297 (Oct. 5, 2018). 28The Commission proposed an amendment to Rule 17g-5(a)(3) that would provide for anexemption from the rule with respect to credit ratings for certain structured financeproducts where the issuer is a non-U.S. person and the NRSRO has a reasonable basis toconclude that the structured finance product will be offered and sold exclusively outsidethe United States. The Commission also proposed conforming amendments to similarexemptions in Rule 17g-7(a) and Rule 15Ga-2. Orders Instituting Cease-and Desist Proceedings. On August 28, 2018, the Commissionissued the following orders pertaining to proceedings regarding certain rating practices atMoody’s:o Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of theSecurities Exchange Act of 1934, Making Findings, and Imposing a Cease-andDesist Order, Release No. 34-83965 (Aug. 28, 2018). 29 The Commissioninstituted settled administrative proceedings against Moody’s concerning itsinternal control structure with regard to the use of certain models in itsmethodology for rating residential mortgage-backed securities.o Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of theSecurities Exchange Act of 1934, Making Findings, and Imposing RemedialSanctions and a Cease-and-Desist Order, Release No. 34-83966 (Aug. 28,2018). 30 The Commission instituted settled administrative proceedings againstMoody’s concerning its policies and procedures designed to define andconsistently apply credit rating symbols. Order Granting Temporary Conditional Exemption for Japan Credit Rating Agency, Ltd.from Certain Requirements of Section 15E(t) of the Securities Exchange Act of 1934,Release No. 34-83884 (Aug. 17, 2018). 31 The Commission granted JCR a temporary,conditional exemption from certain corporate governance requirements under Section15E(t). The exemption expires on August 20, 2021 and thereafter renews until August20, 2023, unless the Commission determines otherwise. Final Rule: Disclosure Update and Simplification, Release Nos. 33-10532, 34-83875,and IC-33203 (Aug. 17, 2018), 83 FR 50148 (Oct. 4, 2018). 32 The Commission adoptedamendments, effective November 5, 2018, to certain disclosure requirements that havebecome redundant, duplicative, overlapping, outdated, or superseded, in light of otherCommission disclosure requirements, U.S. Generally Accepted Accounting Principles(“U.S. GAAP”), or changes in the information environment. The amendments include a28Available at df.29Available at .pdf.30Available at .pdf.31Available at df.32Available at 7
change to Rule 17g-3 to conform the financial statement reporting requirementsapplicable to NRSROs to U.S. GAAP. IV.Order Instituting Administrative Proceedings Pursuant to Section 15E(a)(2)(A)(ii) of theSecurities Exchange Act of 1934 and Notice of Hearing, Release No. 34-83610 (July 9,2018). 33 The Commission issued an order instituting proceedings pursuant to Section15E(a)(2)(A)(ii) to determine whether EJR’s application for registration in the assetbacked securities and government securities credit ratings classes should be granted ordenied.COMPETITIONA.Select NRSRO StatisticsSections 1. through 3. below summarize and discuss certain information reported byNRSROs on Form NRSRO or pursuant to Rule 17g-3 that provides insight into the state ofcompetition among NRSROs. While this information indicates that Moody’s, S&P, and Fitchcontinue to account for the highest percentages of outstanding ratings, other information suggeststhat smaller NRSROs have gained market share in certain asset classes. 341.NRSRO Credit Ratings OutstandingEach NRSRO annually reports the number of credit ratings outstanding, as of the end ofthe preceding calendar year, in each rating category for which it is registered. 35 Thisinformation, for the calendar year ending December 31, 2018, is summarized in Charts 1 through4 below and can be useful in determining the breadth of an NRSRO’s coverage with respect toissuers, obligors, and securities or money market instruments within a particular rating category.Chart 1 depicts the number of credit ratings each NRSRO had outstanding in each ratingcategory for which it was registered as of December 31, 2018. Chart 2 shows the percentage ofcredit ratings each NRSRO had outstanding across all rating categories and also breaks out thepercentages for each NRSRO in each of the rating categories. Chart 3 illustrates the relative sizeof each rating category based on the aggregate number of ratings reported outstanding by allNRSROs. Chart 4 depicts the percentage of ratings each NRSRO had outstanding across allrating categories other than the government securities category.33Available at .pdf.34As discussed in Section IV.B.1. of this Report, information available on the websites of CommercialMortgage Alert (https://www.cmalert.com/) and Asset-Backed Alert (https://www.abalert.com/) regardingNRSRO market shares in the asset-backed securities category indicates that some of the smaller NRSROshave developed significant market shares in such category over the past few years. In addition, SectionIV.B.2. of this Report provides examples of certain asset classes in which it has been reported that smallerNRSROs have gained market share.35Annual certifications on Form NRSRO must be filed with the Commission on EDGAR pursuant to Rule17g-1(f) and made publicly and freely available on each NRSRO’s website pursuant to Rule 17g-1(i). Thenumber of outstanding credit ratings for each rating category for which an NRSRO is registered is reportedon Item 7A of Form NRSRO.8
Comparing the number of ratings outstanding for established NRSROs and newerNRSROs may not provide as comprehensive a picture of the state of competition as comparingthe number of ratings issued by such NRSROs in a given period. Certain NRSROs (particularlythe larger NRSROs) have a longer history of issuing ratings and their ratings include those fordebt obligations and obligors that were rated well before the establishment of the newerentrants. 36 Consequently, the information described in Section IV.B. of this Report (relating torecent market share developments in the asset-backed securities rating category) may provideadditional insight regarding how newer entrants are competing with more established ratingagencies, specifically in the asset-backed securities rating category.There are additional limitations to assessing the state of competition in each ratingcategory and in the aggregate based on the number of outstanding ratings. For instance, someNRSROs have pursued business strategies to specialize in particular rating categories or subcategories 37 and may not desire to issue ratings in certain of the other NRSRO rating categories.Also, the reported information does not reflect any credit ratings being issued by NRSROs inrating categories in which they are not registered with the Commission, nor does it
2019), and DBRS filed an update to Form NRSRO to add Morningstar as a credit rating affiliate. Given that Morningstar and DBRS operated separately during the Report Period and that Morningstar was separately registered as an NRSRO until December 30, 2019, this Report includes information
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Annual Report 2020 compared to our 2019 Annual Report. The total carbon footprint for printing CIMB Annual Report 2020 was 11,588kgCO2e, compared to 14,987kgCO2e for our 2019 annual report. The carbon footprint for the 3 books of CIMB Annual Report 2020 is 14.485kgCO2e. We are committed to reducing the environmental impact of our annual report .
and Meeting Schedules: 6: Annual Report Workgroup Next Steps: Next steps for FY18 report development: 1. HITAC full committee reviews report . FY18 Annual Report Draft discussed: March 1, 2019. FY18 Annual Report Draft discussed: Winter/Spring 2019. FY18 Annual Report completed as needed:
ANNUAL REPORT 2019 ANNUAL REPORT 2019 BEAUTY TECHNOLOGY WELLBEING Sales 2017 2018 2019 1,140m 916m 736m EBITDA 2017 2018 2019 111m 91m 69m Banking Facility 2017 2018 2019 883m 795m 515m 34% United Kingdom 26% Europe 24% Asia Pacific 16% North America Group Sales by R
Annual Report on Nationally Recognized . 25 V. TRANSPARENCY. 26 VI. CONFLICTS OF INTEREST . 2016, 2017, and First Half of 2018. 19 Chart 11: Rating Agency Market Share for Agency CMBS Issued .
