private student loans

Rating Agency Developments

 

On October 17, 2016, DBRS issued a report entitled: CMBS North American SurveillanceReport.

On October 14, 2016, Moody’s issued a report entitled: Moody’s Approach to Rating Securities Backed by Pools of Both FFELP and Private Student Loans. Report.

On October 14, 2016, DBRS issued a report entitled: Global Methodology for Rating Finance CompaniesReport.

Guidance on Private Student Loans With Graduated Repayment Terms Released

On January 29, federal financial regulatory agencies in partnership with the State Liaison Committee (SLC) of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private student loans with graduated repayment terms at origination. Graduated repayment terms are structured to provide for lower initial monthly payments that gradually increase. Financial institutions should provide disclosures that clearly communicate the timing and the amount of payments to facilitate a borrower’s understanding of the loan’s terms and featuresReleaseGuidance.

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies (the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency), in partnership with the State Liaison Committee (SLC) of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private student loans with graduated repayment terms at origination.

This guidance provides principles that financial institutions should consider in their policies and procedures for originating private student loans with graduated repayment terms which are structured to provide for lower initial monthly payments that gradually increase.  The Agencies issued this guidance because they recognize that the competitive job market, traditionally low entry-level salaries, and higher student debt loads can contribute to some borrowers preferring greater flexibility with their payments as they transition into the labor market.  Press ReleasePublished Guidance.

Rating Agency Developments

On January 7, Moody’s published its approach to rating RMBS servicer advance facilities. The rating criteria include: (i) review of the servicer, including assessments of its advance and reimbursement tracking systems and organizational infrastructure, (ii) utilization of servicer-specific historical data on advance reimbursements to determine appropriate stress scenarios and credit risk, (iii) assessment of whether the receivables backing the servicer advance facility are isolated from the bankruptcy risk of the servicer, and (iv) consideration of whether there is a clear alignment of interest between the servicer and the investors.  Moody’s Report.

On January 8, Moody’s issued a new report for rating U.S. floorplan ABS.  Under this approach, Moody’s uses a model to simulate losses based on outcomes related to key risk drivers such as manufacturer or dealer default, payment rates, and economic conditions, supplemented by a static scenario analysis for manufacturers with sub-investment grade ratings, to assess whether Aaa bonds will be resilient to downgrades below investment grade in highly stressed scenarios.  Moody’s also evaluates qualitative factors including the capability and stability of the loan servicer.  Moody’s Release.  Moody’s Report.

On January 8, Moody’s explained its approach to rating securitizations backed by U.S. private student loans.  Moody’s notes that since private student loans do not benefit from a federal guarantee and instead rely on the borrowers’ and co-signers’ credit for repayment, the methodology for rating private student loan securitizations differs significantly from those involving federally insured loans.  Moody’s Release.  Moody’s Report. 

On January 12, Moody’s changed its approach to monitoring credit arbitrage ABCP programs.  The changes are incorporated in the latest version of its public CDO rating model, CDOROM.  Moody’s Release.

On January 13, Moody’s published updates to its methodology on variable rate instruments supported by third party liquidity providers. The changes include updates to the immediate termination or suspension events section of the methodology and effect the assignment of short-term ratings to variable rate demand obligations and commercial paper. Moody’s Report.

On January 13, Moody’s published revised loss projections for some U.S. subprime RMBS issued between 2005 and 2007.  Moody’s Release.

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