Moody’s Investors Services downgraded the subordinate class C and D notes from Capital One Multi-asset Execution Trust (COMET) to ‘Ba1’ from ‘Baa2’ and to ‘B1’ from ‘Ba2’, respectively, citing an increase in the trust charge-off rate and a decrease in the principal payment rate over the past year.

Capital One, unlike other credit card issuers, chose not to add extra credit enhancement to COMET to avoid possible rating downgrades, citing potential adverse reactions from regulators. The company believes Moody’s analysis is wrong, pointing out that other rating agencies do not have the trust on review for downgrade.

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