Fitch: One-Year Cap Would Affect Over Half ABCP-Funded Assets
Data from 12 Fitch-rated European ABCP programmes (all of which are fully supported by liquidity facilities provided by their sponsors) shows that, as at May 2015, slightly more than half (54%) of funded assets have medium- and longer-term maturities and therefore would be ineligible for inclusion in qualifying securitisations under the proposed cap.
All 12 Fitch-rated programmes include assets with maturities exceeding a year, although the proportion varies. In three progammes, all of their assets would be ineligible. In the remaining nine programmes, the proportion of ineligible assets would range from 19% to 86%.
The EBA proposed the one-year maturity cap earlier this month in its response to last year's call for advice on long-term financing of the European Economy by the European Commission. The EBA said a cap would "mitigate refinancing risk and the extent to which [ABCP] embeds maturity transformation" via the issuance of commercial paper which has maturities that cannot extend beyond one year (and is usually under 30 days) to finance longer-term credit claims and receivables.
The proportion of potentially eligible underlying assets under the proposed cap largely reflects the proportion of trade receivables in the asset pool. Trade receivables often have maturities of less than one year, unlike many other ABCP-funded assets (as the EBA proposal notes).
Most of these other assets are auto loans and leases (32% of all funded assets). The remainder includes consumer loans, credit card receivables, equipment leases and loans, and corporate/commercial loans with typical maturities of five to seven years. Only a small proportion (2.1%) is much longer-dated assets, such as residential mortgages.
The EBA also proposed that underlying exposures should have a risk weight under the Standardised Approach no higher than 75% (for retail exposures) or 100% (for any other exposures) on an individual basis. This could prevent transactions backed by claims on low-rated or unrated obligors, such as trade receivables and SME loans, being classified as qualifying securitisations.
We believe the EBA's proposed limit on the aggregate value of exposures to a single obligor (1% of all underlying exposures) would be impossible to monitor due to data protection restrictions and the dynamic nature of the programmes. The limit is meant to ensure a minimum level of granularity, but the most dynamic (and hardest to monitor) asset pools will be those with a high proportion of very granular assets, such as trade receivables and auto loans and leases.
If it were adopted, the full impact of the maturity cap on the ability of existing ABCP programmes and transactions to achieve Qualifying Securitisation status would depend on how the cap were implemented. It is possible that provisions could be made for ineligible assets to be removed, for example. Qualifying Securitisations that met standardised criteria relating to transparency, simplicity, and underlying asset quality would attract lower capital charges than other securitisations under EBA proposals.
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