TEXT-S&P drops rtgs on Cornerstone Titan 2005-2 class D, X nts

Feb 08 -

OVERVIEW

-- The issuer fully redeemed the class D notes on Jan. 23, 2012, following the full repayment of the Trafalgar House Portfolio loan.

-- We have thus withdrawn our rating on the class D notes.

-- At the same time, we have also withdrawn our rating on the class X notes in line with our criteria for rating interest-only securities.

-- The transaction is a 2005-vintage transaction now secured against two U.K. commercial property loans.

-- These ratings are based on our criteria for rating European CMBS. However, these criteria are under review. As a result of this review, our future European CMBS criteria may differ from the current criteria. The criteria change may affect the ratings on all outstanding notes in this transaction.

Standard & Poor's Ratings Services today withdrew its 'AA- (sf)' credit rating on Cornerstone Titan 2005-2 PLC's commercial mortgage-backed class D notes following their redemption. At the same time, we have also withdrawn our 'AA- (sf)' rating on the class X notes in line with our criteria for rating interest-only securities. All other rated classes of notes are unaffected (see list below).

As per the January 2012 cash manager report, the class D notes fully redeemed on Jan. 23, 2012, following the full repayment of the Trafalgar House Portfolio loan. We have thus withdrawn our rating on this class of notes.

At the same time, we have also withdrawn our rating on the class X notes in line with our criteria for rating interest-only securities (see "Global Methodology For Rating Interest-Only Securities," published on April 15, 2010). For interest-only securities that reference either the entire asset pool of a transaction or an amortization schedule or formula, we maintain their current ratings until all principal- and interest-paying classes rated 'AA-' or higher have been retired or downgraded below that rating level--at which time we will withdraw these interest-only ratings.

The other rated notes in this transaction remain unaffected by today's rating action.

Cornerstone Titan 2005-2 closed in 2005 with notes totaling GBP398.7 million. The notes have a legal final maturity date in October 2014.

POTENTIAL EFFECTS OF PROPOSED CRITERIA CHANGES

Our ratings in this transaction are based on our criteria for rating European commercial mortgage-backed securities (CMBS). However, these criteria are under review (see "Advance Notice of Proposed Criteria Change: Methodology And Assumptions For Rating European Commercial Mortgage-Backed Securities," published on Nov. 8, 2011).

As highlighted in the Nov. 8 Advance Notice of Proposed Criteria Change, we expect to publish a request for comment (RFC) outlining our proposed criteria changes for rating European CMBS transactions. Subsequently, we will consider market feedback before publishing our updated criteria. Our review may result in changes to the methodology and assumptions we use when rating European CMBS, and consequently, it may affect both new and outstanding ratings on European CMBS transactions.

Until such time that we adopt new criteria for rating European CMBS, we will continue to rate and surveil these transactions using our existing criteria (see "Related Criteria And Research").

STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a credit rating relating to an asset-backed security as defined in the Rule, to include a description of the representations, warranties and enforcement mechanisms available to investors and a description of how they differ from the representations, warranties and enforcement mechanisms in issuances of similar securities. The Rule applies to in-scope securities initially rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report included in this credit rating report is available at