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Global Rating Methodologies Global Rating Methodology for ...

7 World Trade Center at 250 Greenwich Street New York, New York 10007 November 28, 2007 Re: NAIC Hearing on Use of Catastrophe Modeling by Rating Agencies Dear Ms. Simpson: We appreciate the opportunity to comment on the use of catastrophe modeling by moody s Investors Service in analyzing property & casualty insurers and reinsurers. moody s provides insurance financial strength ratings to property and casualty insurers and reinsurers and those ratings express our opinions of the ability of insurance companies to repay punctually senior policyholder claims and obligations. These ratings reflect our opinion of long-term relative risk and are forward-looking in nature because they apply to liabilities that may pay out over long periods of time. moody s analytical approach includes significant qualitative analysis in addition to quantitative analysis, and incorporates the opinions and judgments of experienced analysts.

z Page 2 November 28, 2007 Adjusted Capital Model (MRAC) for primary companies and (3) Moody’s Probability of Default and Expected Loss Modeling for reinsurers and structured vehicles.

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