CUSIP Guidelines

Effective October 19, 2011

Table of Contents
What is a CUSIP? What are the benefits of utilizing CUSIPs for the Syndicated Loan Market? CUSIPs are required for market initiatives Who should apply for CUSIPs? Deals that require CUSIPs When should a CUSIP be applied for? CUSIP Application Process Key Events and Modifications Agents should amend the data in the CUSIP system Change in the Name of the Borrower Terminated facilities of an active deal Data Cleansing Inclusion of Deal and Facility CUSIPs How to reflect the transfer of a Deal to a new Agent Cost of a CUSIP Market Penetration of CUSIP Exhibit A Exhibit B 3 3 3 4 4 5 5 6 7 8 8 8 8 9 9 9 10 14

CUSIP GUIDELINES

What is a CUSIP? CUSIP numbers uniquely identify financial instruments in the United States and Canadian financial markets. The CUSIP number consists of 9 alphanumeric characters. It is issued by CUSIP Global Services (CGS) which is operated by Standard & Poors under license from the American Bankers Association. CUSIP numbers identify a wide variety of financial instruments including, without limitation, stocks, bonds, commodities and syndicated loans.

What are the Benefits of utilizing CUSIPs for the Syndicated Loan Market? The market-wide adoption of CUSIPs benefits all market participants including agents, dealers, buy-side institutions, rating agencies, pricing services, settlement platforms and regulators by: Enabling a more orderly exchange of information in an automated environment Facilitating proper crediting of money movements, Facilitating automated loan trading, pricing services and rating agencies by creating a common reference for market pricing and ratings, Improving communication and reporting capabilities related to the settlement process, Complying with the regulatory requirements of the banking and insurance supervisory agencies to uniquely identify portfolio assets in accordance with generally accepted standards and protocols and Focusing inquiries.

CUSIPs are REQUIRED in order to utilize: LoanServ Position Reconciliation Platform Markit Clear Trade Matching Platform Loan/SERV Cash on Transfer FpML Messaging

Who should apply for CUSIPs? No entity or individual, other than the Administrative Agent (the Agent), will be able to apply for CUSIPs on deals and facilities that are administered by such Agent. Prior to applying for CUSIPs, each Agent is required to complete a Master Registration Letter in the form set forth on Exhibit A hereto wherein a minimum of two people (Special Authorized Persons) from each Agent should be designated to authorize certain individuals (Authorized Representatives) within their institution to apply for CUSIPs. In addition, should Special Authorized Persons wish to provide view only access rights, to their institutions CUSIPs, to additional personnel within their institution, such Special Authorized Persons shall provide a list of such individuals to CGS via e-mail at Cusip_loan@cusip.com. Agents must maintain a current active list of employees who (i) are permitted to apply for CUSIPs and (ii) who can just view their CUSIPs in a read-only fashion. Any changes to such list must be provided promptly to CGS at Cusip_loan@cusip.com.

Deals that require CUSIPs: The domicile of the primary obligor or such first named borrower under the draft or execution version of the Credit Agreement (hereinafter referred to as the Borrower) is the determining factor for whether CUSIPs or CUSIP International Numbers (CINS) will be issued. If the Borrower is domiciled in the United States, then CGS will issue CUSIPs and US ISINs; if the Borrower is not located in the United States, CGS will issue CINS and an XA ISIN. In light of FpML messaging initiatives, Agent Banks should obtain CUSIPs for all leveraged and investment grade deals, including club deals, that meet the criteria set forth within the Shared National Credit (SNC) definition below. Bilateral deals do not require CUSIPs; however, CUSIPs on bilateral deals may be applied for at the discretion of the Agent. By way of background: A SNC must have an original deal amount on the closing date that aggregates $20 million or more and either 1) is shared by three or more unaffiliated supervised institutions under a formal lending agreement or 2) a portion is sold to two or more unaffiliated supervised institutions with the purchasing institutions assuming their pro-rata share of the credit risk. A supervised institution is one which is subject to supervision by one of the federal bank regulatory agencies, including all FDIC-insured banks, their branches, subsidiaries, and affiliates; bank holding companies and their non-bank subsidiaries and affiliates; and federal and state-licensed branches and agencies of foreign banks. While CUSIPs are one of a number of Syndicated Credit Data Elements requested by the Federal Reserve, as of today, they are not required. The loan market cannot mandate the usage of CUSIPS for Shared National Credit Reporting; nevertheless, if CUSIPs are available, they should be included in the reports.
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When should a CUSIP be applied for? CUSIPs should be applied for on a when issued basis, two Business Days prior to the final allocation of a deal. A Business Day is defined as a day other than a Saturday, Sunday, or other day on which commercial banks in the governing jurisdiction are authorized or required by law to close. Such application is made based on either a draft or execution version of the credit agreement. CUSIPs are issued by CGS based on such preliminary data (as is typical in the equity market.) within one Business Day of application unless one applies for expedited service in which case CUSIPs can be issued within one hour. Since the deal has not closed when CUSIPs are issued, the Agent will determine if the deal, and therefore the respective deal and facility CUSIPs, are to be released into the Syndicated Loan Service (Published) or are to remain unlisted (Unpublished). Unpublished CUSIPs will be provided by CGS to the Agent only. CUSIPs should be populated into systems (e.g. the trading system, syndication system, agent system, settlement system) prior to the closing of the deal CUSIPs must be provided to the buy-side upon allocation, regardless of whether or not they are Published or Unpublished. Appropriate modifications and additions to the application (e.g. Credit Agreement Date and Maturity Date) should be submitted via the online CUSIP System as the deal progresses toward finalization with final data provided to CGS upon the closing of the deal. All information provided in the CUSIP application, including the name of the Borrower, may be amended or modified without changing the CUSIP number. Every effort should be made to publish CUSIPs, previously designated as Unpublished, once the deal closes. At a minimum, CUSIPs which identify (i) the debt of publicly traded companies or (ii) debt, evidence of which is publicly available through SEC filings or EDGAR, should be Published.

CUSIP Application Process The following steps must be taken to apply for CUSIPs on all Leveraged and Investment Grade Deals and Facilities that meet the SNC criteria: The Agent must complete the following data fields in the CUSIP application: a. Full Legal Name of the Borrower. b. Borrowers Country of Domicile. c. Borrowers State of Incorporation (if domiciled in the United States).
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d. e. f. g.

h.

i. j. k. l.

Credit Agreement Date. Deal Amount. Deal Currency. Facility Type (e.g. Term Loan, Revolver/Standard, Revolver/Term, etc. which can be chosen from the drop-down menu as set forth on Exhibit B hereto) Facility Purpose Description / (The legal definition of the facility as set forth in the Credit Agreement. There is an option in the purpose field to include a free form text in which the EXACT legal definition of the facility set forth in the Credit Agreement should be inserted if it is not already included within the drop-down options set forth on Exhibit B hereto (e.g. Term Loan A, Term Loan A-1, 364 Day Revolver, etc.) Therefore, use the drop down menu ONLY if the exact legal definition appears in such menu. Facility Amount Facility Currency Facility Maturity Date (final repayment date for the facility) Publication flag choose to publish or unlist; the default is that the deal will be Unpublished.

Key Events and Modifications: Deals that require the issuance of new CUSIPs A deal is considered to be terminated when (a) all existing facilities and outstanding interest, fees, and/or other obligations due and owing by the obligors under such credit agreement have been repaid in full or (b) all commitments have been reduced to zero. A deal will also be considered to be terminated when a credit agreement that has been entered into and made effective contains a condition precedent to such effectiveness that the earlier deal and its respective credit agreement must be terminated prior to the latter agreements effectiveness. In its simplest format, when an original deal is terminated and a new deal is issued, an application for new deal and facility CUSIPs must be submitted pursuant to the rules above, that is, so that CUSIPs are available upon the final allocation of such new deal. The deal and facility CUSIPs belonging to the now terminated original deal must be simultaneously terminated upon the closing of such new deal. Note that CUSIP numbers from the original deal will only be terminated when the Agent submits a specific termination request to CGS. It is important to note that CUSIPs are also required when the first deal remains in effect but in addition, a new deal is entered into in parallel such that two distinct sets of deal and respective facility CUSIPs are in effect.
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Deals that are Amended and/or Extended: With respect to any deal that is amended and/or extended, the CUSIP is retained with respect to the original facility (consent was not received for it to be amended) and a new CUSIP must be applied for with respect to the new facility that is created (where consent was received) for the portion of additional debt with a different pricing and/or extended maturity date. A deal that is only amended does not require a new Deal CUSIP nor does it require new CUSIPs for pre-existing facilities. However, as stated above, if a new facility is created pursuant to the amendment, an application must be submitted requesting a CUSIP for such new facility. Such application should be made two Business Days prior to the final allocation of the new facility. If an existing facility maturity date is extended, such extended date must be submitted to the CUSIP system and a revised facility maturity date will be included in the data. Such revisions should be made within one Business Day of the signing of the Amendment. If a facility is modified, typically for the commitment amount or maturity date, it is necessary to amend the data; it is not necessary to apply for a new CUSIP. Facilities with regular extensions retain the same CUSIP numbers; however, the maturity dates must be amended in the CUSIP file. Therefore, a 364-day evergreen facility does not require a new CUSIP; however, its data must be modified in the CUSIP system to reflect a new facility maturity date.

Thus Agents should amend the data in the CUSIP system to reflect: A change in a Commitment, including any increase or decrease through an amendment or accordion. For example, if the original commitment was $500MM, $50MM was paid down and pursuant to an amendment the commitment was increased by $100MM, the amended Commitment Amount is $550 since this is the actual commitment at the time of the amendment. A change in a Maturity Date The addition of a Facility The termination of a Facility The Credit Agreement Amendment Date A change in the name of the Borrower If any of the foregoing result in a change in deal size, such deal size should be amended. For example, if the original deal had a $500MM term (which is now $550MM) and the original revolver was $500MM (and this is amended to $300MM) the original Deal Amount of $1MMM is now an amended Deal Amount of $850MM. There is no requirement to amend CUSIP data to reflect permanent paydowns or PIK. However, keep in mind that if there is a separate PIK Facility, set forth in the
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Credit Agreement or an amendment thereto, a CUSIP should be applied for and issued with respect to such facility. Global deal validation will be undertaken by the CUSIP System; the total deal amount will reflect any modification/termination and subsequent addition.

Change in the Name of the Borrower Agents may retain the original CUSIP numbers and deal/facility information while changing the name of the Borrower on such deal/facility (Revised Borrower). Agents must specify the corporate action resulting in such change by inserting the specific action into an open text field. Examples of corporate actions include, without limitation,: (i) reorganization, (ii) merger and (iii) acquisition. Agents must send a copy of the document evidencing such corporate action via e-mail to CGS at Cusip_loan@cusip.com. Both the original Borrower and Revised Borrower names are presented in the deal information fields on the CUSIP system.

Terminated Facilities of an Active Deal When a deal is still active, any terminated facilities should be flagged by the Agent as terminated. While such facility is not included within the amended deal amount, it is still included within the deal data in the CUSIP system.

Data Cleansing Agents must continually scrub data to verify its correctness while simultaneously terminating CUSIPs on deals/facilities that have been terminated.

Deal and Facility CUSIPs should be included on each of the following: Documentation that is distributed when a new deal is brought to the market, e.g. early draft versions of the credit agreements should include a placeholder for deal and facility CUSIPs, if the actual CUSIP numbers are not available. Vendor platforms used in connection with syndicating deals and facilities. Ratings which are provided prior to a deals closing and thereafter. Allocations provided by the Syndication Desk/Sales Desks to the potential lenders. The cover page of Credit Agreements The cover page of Amendments (in this case only the deal CUSIP and Facility CUSIP(s) for any new facility/facilities issued specifically under such Amendment). The mark-to-market pricing services Vendor platforms used to settle trades and reconcile positions
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Trade Documentation: trade tickets, trade confirmations, assignment and acceptance agreements, funding memos and any other documentation pertinent to settlement. Agent Bank notices provided throughout the duration of the deal (drawdowns, interest payments, principal payments, rate resets, rollovers, fees). Accounting systems of all loan market participants (including, without limitation, Agents, buy-side institutions, dealers, custodians, trustees and fund administrators to identify the deals and facilities. How to reflect the transfer of a Deal to a new Agent When the Administrative Agent function for a credit is transferred from one Agent to another, it is not necessary for the new Agent to re-apply for new CUSIPs; however, in order for ownership of the Deal and facility CUSIPs to be transferred to the new Agent a copy of an executed Resignation and Assignment or similar document, must be emailed to CGS at Cusip_loan@cusip.com by either the new or the predecessor Agent. The original CUSIPs will still be effective. CGS will transfer access to the CUSIPs from one Agent to the new Agent. If the new Agent has not applied for CUSIPs before, Ellen Hefferan will coordinate having the new Agent complete a Master Registration Agreement. The new Agent will then have the ability to maintain and amend such CUSIPs, when necessary. Cost of a CUSIP: The price of a deal level CUSIP is currently $550; the price of a facility level CUSIP is $50.

Market Penetration of CUSIPs: In order to have market penetration of CUSIPs it is important that all Agent Bank notifications, sent to lenders of record, include deal and facility CUSIP numbers. Lenders should incorporate CUSIPs into their respective front, middle, back office and accounting systems and further should provide CUSIPs to their custodians, trustees and fund administrators. Again note that Deal and Facility CUSIPs MUST be populated in the systems of the Agents, dealers and buy-side institutions so that such systems will be integrated with the following: LoanServ Position Reconciliation Platform Markit Clear Inventory/Trade Matching Platform Loan/SERV Cash on Transfer FpML Messaging hubs/services
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Exhibit A
Form of Master Registration Letter Dated as of January, 2011 [Date] CUSIP Global Services Standard & Poors The McGraw Hill Companies h 55 Water Street, 45 Floor New York, New York 10041 Attention: CUSIP Syndicated Loan Unit To whom it may concern:

The undersigned is a duly authorized officer of [NAME OF INSTITUTION] ([Short Name of Institution]), which acts as agent for record keeping, payments processing and fundings under syndicated credit facilities (in such capacity, the Agent). T he undersigned hereby submits on behalf of [Short Name of Institution] this Master Registration Letter in connection with its registration and qualification to apply for Syndicated Loan CUSIP Numbers by submitting Requests for CUSIPs for Loans (Applications) through the CUSIP Global Services (CGS) web-based application in accordance with streamlined procedures designed for administrative agents with responsibility for performing the record keeping, payments processing and funding mechanics functions for syndicated loans (the Registered Agent Application Procedure).

Each of the persons whose names appear in Part I-A of Annex A hereto has been designated by [ Short Name of Institution] as one of its Special Authorized Persons with specific authority to (i) execute this Master Registration Letter and (ii) select, identify and submit to the CGS the names of [ Short Name of Institutions] Authorized Representatives in accordance with item 4 below. No change in the list of Special Authorized Persons or Authorized Representatives shall be effective unless submitted to CGS in writing by a Special Authorized Person. Delivery by email to cusip_loan@sandp.com of a substitute Annex A shall satisfy such writing requirement.

Registered Agent Responsibilities. [Short Name of Institution] hereby represents, warrants and agrees that in connection with any Application for Syndicated Loan CUSIP Numbers made pursuant to the Registered Agent Application Procedure it shall: 1. Comply with the procedures for the Registered Agent Application Procedure adopted by the CGS and the Loan Syndications and Trading Association, Inc. (the LSTA) as set forth in the LSTA Manua l for Syndicated Loan CUSIP Numbers (the Manual). 2. Use the Registered Agent Application Procedures to submit Applications only for those loan facilities for which it is the duly authorized Agent. 3. Take reasonable precautions designed to ensure that only the respective individuals named herein or pursuant hereto as Authorized Representatives of [Short Name of Institution] have access to the User ID and password assigned to such individual by CGS. 4. Submit to CGS in writing in substantially the format set forth in Part I-B of Annex A hereto the names of the Authorized Representatives who are permitted by [Short Name of Institution] to apply for Syndicated Loan CUSIP Numbers on its behalf in accordance with the Registered Agent Application Procedure. 5. Provide to CGS all of the identifying information required to be completed in the Application for Syndicated Loan CUSIP Numbers in the sections identifying the company making the Application, such information and [Short Name of Institution]s billing information being referred to herein as the Static Data. Static Data does not include the first and last names of the Authorized Representative completing the Application or such individuals telephone number and email address. 10

S&P Agreements. S&P hereby represents, warrants and agrees that it shall comply with the procedures and requirements set forth in the Manual and that (i) the Application for Syndicated Loan CUSIP Numbers has been designed to prevent changes to the Static Data to be made except by CSB personnel at the written instruction of Special Authorized Persons or Authorized Representatives of [ Short Name of Institution] and (ii) the Static Data shall not be capable of being altered online by personnel of [ Short Name of Institution].

User ID and Password. Upon receipt by CGS from [Short Name of Institution] of names of Authorized Representatives (whether at the time this Master Registration Letter is executed, or subsequent thereto by delivery of a revised Annex A), CGS shall promptly return to each new Authorized Representative by email or other secure electronic method a unique User Identification Number and password to enable such individual to make Applications for Syndicated Loan CUSIP Numbers on behalf of [ Short Name of Institution]. In the event an Authorized Representative wishes to change her/his password, s/he may do so by emailing such request to CGS at cusip_loan@sandp.com. Lender Applicant Requests. In the event that a lender under a credit facility (a Lender Applicant) for which [Short Name of Institution] acts as Agent submits an Application in accordance with the procedures designed therefor, the following restrictions and procedures shall apply: 1. CGS shall observe the following restrictions in connection with Lender Applicant Applications: a. In the event that a Lender Applicant submits an Application in connection with a deal for which CUSIP Numbers have been assigned pursuant to Application by the Agent therefor, CGS shall not process such Lender Application. b. CGS shall not process Lender Applicant Applications for credits for which [ Short Name of Institution] acts as Agent until 10 Business Days after the date as of which the credit agreement is dated (the Credit Agreement Date); pro vided, however, that the Agent may by notice to CGS extend the period during which Lender Applicant requests shall not be processed if the Credit Agreement Date is substantially earlier than the date of execution of the credit agreement by the parties thereto. 2. CGS shall notify [Short Name of Institution] of any Application made by a Lender Applicant that is not prohibited by the provisions hereof, and [ Short Name of Institution] shall have the option to elect to: a. submit an Application for Syndicated Loan CUSIP Numbers for such facility(ies) and the associated deal and other associated facilities (if any); or b. verify with CGS (and complete to the extent necessary) the description of the facility(ies) and the associated deal and other associated facilities (if any) for which Application is being made, and verify that the Applicant is a lender therein; provided, however, that in the event that [ Short Name of Institution] either (i) does not within 30 calendar days of receipt of such notice from CGS submit an Application or provide such information or (ii) declines to provide such information, CGS shall be permitted to request from the Lender Applicant such documentation as may be reasonably necessary for CGS to perform such verification without assistance from [Short Name of Institution]. 3. CGS shall send [Short Name of Institution] a copy of the confirmation of any issuance of a CUSIP Number to a Lender Applicant, such confirmation to be sent to the Agents group e -mail Address, if any, that [Short Name of Institution] has elected in Part II of Annex A hereto, or to the e-mail address of such Authorized Representative as the Agent has directed in Annex A hereto. Billing. [Short Name of Institution] shall receive from CGS monthly invoices for fees associated with issuance of CUSIPs requested by [Short Name of Institution], on a billing cycle that runs daily. Such invoices shall be delivered within 30 days after CUSIP number is assigned. The following information shall be set forth for every invoice for which CUSIP Numbers were assigned at the request of [Short Name of Institution]: Borrower Name, deal level CUSIP number and the fee therefor, date requested, credit agreement date, global deal amount, and each facility level CUSIP number and the respective fee therefor. 11

Billing Code, Agent ID Numbers. CGS shall assign and furnish to [Short Name of Institution] a single Billing Code that will capture all activity relating to CUSIP numbers for syndicated loans requested by [Short Name of Institution] as Agent in accordance with these Registered Agent Application Procedures. Such Billing Code is set forth in Part IV of Annex A hereto. In addition, CGS shall assign and furnish to [Short Name of Institution] an Agent ID Number; provided however that in the event [Short Name of Institution] uses two or more legal entities to act as administrative agent for syndicated lending transactions, it shall elect in Part IV of Annex A hereto whether it wishes each such legal entity to have its own unique Agent ID Number or whether all such entities shall share one Agent ID Number. Every deal (and its constituent facilities) is associated with a single Agent ID Number; Authorized Representatives can view information relating only to those CUSIP Numbers associated with an Agent ID Number for which such Authorized Person has been granted permission. Acceptance, Amendments in Writing, Etc. S&P shall evidence its satisfactory review and approval of this Master Registration Letter by duly executing the acceptance below. This Master Registration Letter comprises the complete and integrated agreement of the parties hereto relating to the subject matter hereof and supersedes all prior agreements, written or oral. No amendment, modification or other change affecting any provision of this Master Registration Letter shall be valid unless in writing and signed by a Special Authorized Person on behalf of [Short Name of Institution]. The words execution, signed, signature, delivery and words of like import shall be deemed to include ele ctronic signatures and the delivery or maintenance of records in electronic form. S&P shall return a copy of this letter to the undersigned representative of the Agent. [FULL LEGAL ENTITY NAME OF AGENT INSTITUTION]

BY:

_______________________________________

NAME: _______________________________________ TITLE: _______________________________________

ACCEPTED AND AGREED AS OF __________________________ __, 20__ STANDARD & POORS CUSIP GLOBAL SERVICES, a division of THE MCGRAW HILL COMPANIES, INC.

BY:

___________________________________________

NAME: ___________________________________________ TITLE: ___________________________________________

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ANNEX A DATED AS OF ________________, ____ Administrative Details I-A. Special Authorized Persons NAME TITLE/FUNCTION Phone EMAIL ADDRESS

I-B. NAME

Authorized Representatives TITLE/FUNCTION PHONE EMAIL ADDRESS

II. Option to require CGS to use a group e-mail address for agent communications The following is an optional requirement that any Agent may elect by supplying a group e-mail address below: [Short Name of Institution] has elected to use a group e-mail address for its internal administration of CUSIP numbers. Any notice, confirmation or other correspondence sent to an Authorized Representative must also be sent to the following group e-mail address: _______________________________. In addition, any notice or other correspondence of a general or administrative nature (including copies of Lender Applicant Requests) shall be sent to such Group e-mail address. III. BILLING INSTRUCTIONS FOR [SHORT NAME OF INSTITUTION]: NAME OF INDIVIDUAL NAME OF INSTITUTION ADDRESS TELEPHONE: XXX.XXX.XXXX EMAIL: ____________________ THE FOLLOWING INFORMATION IS USED BY CGS AND THEREFORE SHOULD REMAIN BLANK Billing codes and Agent ID The Billing Code for [Short Name of Institution] is: ______________________________ [SHORT NAME OF INSTITUTION] CONDUCTS ITS ROLE AS AGENT FOR SYNDICATED LENDING TRANSACTIONS THROUGH THE FOLLOWING LEGAL ENTITIES AND REQUESTS THAT [EACH SUCH LEGAL ENTITY BE ASSIGNED A UNIQUE AGENT ID NUMBER] [ALL SUCH LEGAL ENTITIES BE ASSIGNED A SINGLE AGENT ID NUMBER]. [Legal Entity Name] [Legal Entity Name] [Legal Entity Name] Agent ID Number:__________________________________ [Agent ID Number:__________________________________] [Agent ID Number:__________________________________]

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EXHIBIT B FACILITY TYPE DELAYED DRAW/MULTI-DRAW TERM LOAN REVOLVER/REDUCING REVOLVER/REDUCING/TERM REVOLVER/STANDARD REVOLVER/TERM TERM LOAN LETTER OF CREDIT DEPOSIT FUNDED FACILITY FACILITY DESCRIPTION >364-Day Revolver 364-Day Revolver Acquisition ABL Bridge Facility Construction Debtor-In-Possession Deposit Funded Facility First Lien Institutional Term Loan Letter of Credit PIK Facility Revolver Term Out Second Lien Term Loan Term Loan A Term Loan A-1 Term Loan A-2 Term Loan A-3 Term Loan A-4 Term Loan B Term Loan B-1 Term Loan B-2 Term Loan B-3 Term Loan B-4 Term Loan C Term Loan C-1 Term Loan C-2 Term Loan C-3 Term Loan C-4 Term Loan D Term Loan D-1 Term Loan D-2 Term Loan D-3 Term Loan D-4 Term Loan E Term Loan E-1 Term Loan E-2 Term Loan E-3 Term Loan E-4 Term Loan F Term Loan F-1
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Term Loan F-2 Term Loan F-3 Term Loan F-4 Term Loan G Term Loan G-1 Term Loan G-2 Term Loan G-3 Term Loan G-4 Term Loan H Term Loan H-1 Term Loan H-2 Term Loan H-3 Term Loan H-4 Third Lien Working Capital

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