Fitch Publishes Exposure Draft for Rating Closed-End Fund Debt and Preferred Stock
The agency will continue to apply its current criteria until the finalization of the revised criteria which Fitch expects to publish in September 2015 following the review of comments received during the consultation period. At this time, no ratings changes are expected. While Puerto Rico closed-end funds (CEFs) have the potential to be negatively impacted given higher exposures PR issuers, the funds are currently actively de-levering and reducing the exposure of rated notes to PR issuers. Comments and feedback can be sent to cef.feedback@fitchratings.com.
Feedback is sought on the following proposed changes:
--Fitch proposes to amend issuer concentration guidelines for state-level general obligation (GO) exposure. In the event that the rating of a U.S. state or territory falls below investment grade, higher GO issuer concentration guidelines will no longer apply and will be reviewed under the base issuer diversification framework. Fitch's base issuer concentration guideline is 10% for the largest obligor. If the largest issuer is an investment-grade rated state-level GO or another issue backed by a state-level taxing authority, this concentration threshold increases to 20% under Fitch's 'AAA' criteria, and is higher for lower rating levels. The previous state-level GO concentration framework was intended to promote an appropriate amount of portfolio diversification without creating an incentive for portfolios to diversify away from what traditionally is the most creditworthy and liquid municipal issuer in a given state. It's Fitch's view that that this benefit substantially decreases when state-level GO is downgraded to below investment-grade ('BB+' or lower) and, therefore, will no longer apply.
--Fitch also proposes to consolidate the following sector and sub-sector criteria reports which were previously published separately for U.S. CEFs, PR CEFs, Non-U.S. CEFs and Market Value structures. The criteria are listed below:
--'Rating Closed-End Fund Debt and Preferred Stock, Sept. 4, 2014;
--'Rating Market Value Structures', Sept. 4, 2014;
--Rating Puerto Rico Closed-End Fund Debt and Preferred Stock', Sept. 4, 2014;
--'Rating Debt and Preferred Securities Issued by Non-US Closed-End Funds', March 18, 2014.
With the exception of the concentration proposal noted above, the core rating methodology from these separate criteria reports remain intact. Fitch is seeking market feedback regarding whether this change impacts the transparency of the criteria or rating process.
KEY RATING DRIVERS
Fitch's total and net overcollateralization (OC) tests outlined in the criteria measure the ability of a CEF (or related other value structure) to redeem debt and preferred stock through liquidation of portfolio assets during stressed market conditions. The tests also reflect the amount of portfolio diversification, the degree of subordination risk for rated leverage, and the full leverage profile of the fund (including economic leverage from the use of derivatives).
Other Key Rating Drivers:
--Fund limits to leverage stemming from regulatory asset coverage or other leverage/asset coverage tests;
--The presence of dynamic deleveraging/defeasance triggers;
--The amount of risk-adjusted OC available to rated debt and preferred stock;
--The liquidity, historic volatility and diversification of portfolio assets;
--The capabilities of the investment manager to successfully manage fund investment and leverage strategies;
--Legal/regulatory parameters that govern fund operations.
The exposure draft, titled 'Rating Closed-End Fund Debt and Preferred Stock' (July 31, 2015), is available at 'www.fitchratings.com'.
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