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STRUCTURED FINANCE RESEARCH

Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens
Primary Credit Analyst: Mark S Boyce, London 02071768397; mark.boyce@standardandpoors.com Secondary Contact: Andrew H South, London (44) 20-7176-3712; andrew.south@standardandpoors.com

Table Of Contents
Some European Securitization Sectors Have Recovered The Weak Economy Is Depressing Loan Growth Official Support For The Banking Sector Has Provided Cheaper Funding Alternatives To Securitization New "Bail In" Rules Could Lead Banks To Rely More On Secured Funding The Stigma Surrounding Securitization Is Starting To Fade, But Regulatory Treatment Remains Harsh Post-Crisis Demand For Securitizations Is StrongFor Now Related Research

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens
(Editor's Note: This article is part of a series examining the dynamics of debt in Europe and how this will shape the path to recovery.) In the years leading up to the global financial crisis, securitization was a significant funding source for lending to European consumers and corporations. For example, in 2007, the volume of new residential mortgage-backed securities (RMBS) issuance was equivalent to about one third of gross mortgage lending in each of the U.K., Netherlands, Spain, and Ireland. Investor-placed securitization dried up during the depths of the downturn, but more recently, some sectors have seen a revival, and issuance could be about 60 billion this year. Although that remains low in absolute terms compared with the early 2000s, when considered relative to lending volumes for the underlying collateral, some asset classes are once again close to pre-crisis levels. New issuance is coming both from long-established programs and from debut transactions by originators that are turning to securitization technology for the first time. Meanwhile, high spreads relative to other asset classes and regions mean European securitization is attracting both seasoned and new investors. This all suggests thatfor some market practitioners, at leastthe appeal of securitization has not been diminished by its association with the financial crisis. Overview Following a sharp retrenchment five years ago, securitization issuance is once again funding a substantial proportion of certain types of lending in some European countries. The pace at which issuance continues to pick up in the coming years will depend on several factors, including the strength of Europe's economic recovery, and how soon central banks and governments withdraw funding support from the financial system. As currently drafted, we believe that proposed new regulations threaten a more complete longer-term recovery of the European securitization market, as they could dramatically reduce the sector's attractiveness for some investorsnotably banks, insurers, and pension funds. However, there is some evidence that the political and regulatory stance toward securitization may be softening.

A more substantial recovery of the European securitization marketand its long-term role as a funding source for real-economy lending and as a risk transfer mechanism for bankswill depend on several factors, in Standard & Poor's Ratings Services' opinion. Even if the securitization market may be ready to fund more lending, issuance will likely not rise significantly until banks' and other institutions' lending appetite increases and private sector credit demand rises, pushing up underlying lending volumes. This in turn may depend on broader sentiment and progress with recapitalization of the banking sector. In addition, some lenders, especially in southern Europe, may already have

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

prefunded a significant part of their future financing requirements with central bank borrowing, reducing their short-term need to fund in the private sector generally, including via securitization. However, the largest effect on the long-term future of European securitization will likely come from the ultimate shape of revisions to capital and liquidity rules for financial institutions, in our view. For example, as currently drafted, we believe that proposed changes to the Basel securitization framework and the treatment of securitization exposures under Solvency II would represent a significant threat to the European market. That said, there are indications that the stigma surrounding the sector is starting to fade, and there seems to be increasingly positive sentiment among certain European policymakers toward so-called "responsible securitization". Whether the eventual implementation details of various regulatory initiatives reflect this shifting mood remains to be seen.

Some European Securitization Sectors Have Recovered


European securitization issuance began to accelerate in the early 2000s, with investor-placed issuance peaking at more than 500 billion in 2006nearly one quarter of eurozone (European Economic and Monetary Union) GDP (see chart 1). The tranched nature of securitizations allows originators to tailor the risk and maturity profiles of their debt issuance to differing investor bases, resulting in a cost-efficient and more diverse source of funding, whose maturity often matches that of the assets it finances.

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 1

Securitization therefore became a significant means of funding lending to the real economy. For example, the volume of annual RMBS issuance was equivalent to more than 30% of gross residential mortgage lending in several Western European countries by mid-2007 (see chart 2). Similarly, in the U.K.the largest European commercial real estate (CRE) marketcommercial mortgage-backed securities (CMBS) issuance as a proportion of gross CRE lending also peaked at 30% in 2005 (see chart 3). In 2006, collateralized loan obligations (CLOs) were effectively financing about 40% of new European leveraged loans, typically made to speculative-grade corporations (see chart 4). Securitization also contributed significantly to other areas of lending activity. Volkswagen Banka captive finance subsidiary of the largest European auto manufacturer by registrationsissued its first auto asset-backed securities (ABS) in 2004. Within three years, more than one third of the lender's retail financing contracts were securitized. In the five years to 2008, some of the biggest Spanish lenders, including Banco Santander S.A., Banco Bilbao Vizcaya Argentaria S.A., Banco de Sabadell S.A., and Banco Popular Espaol S.A., along with several smaller savings banks (or "cajas"), securitized loans to small and midsize enterprises (SMEs) in CLO transactions.

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 2

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 3

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 4

When the financial crisis hit European securitization issuance fell sharply, as investors retreated from the market. Many bank originatorsincluding those who no longer had access to private sector fundingcontinued to structure transactions, but retained most of the issuance on their own balance sheets for potential use as collateral to secure borrowing from central banks. However, in the past two years, some securitization sectors have begun to resurface, following strong demand from European and, increasingly, international investors. In 2012, German auto ABS and U.K. credit card ABS issuance was back to pre-2008 levels. While still significantly down from their peak in absolute terms, U.K. and Dutch RMBS volumes returned to constitute about one quarter of mortgage lending last year. In the U.K., five building societies debuted RMBS transactions in 2011 and 2012, suggesting that securitization remains attractive to new as well as longstanding originators. The European leveraged loan CLO market saw 14 new transactions in the first nine months of 2013 following a five-year drought, and European CMBS issuance reached 6 billion, compared about 2 billion in all of 2012. By contrast, some other sectors have yet to return significantly. For example, RMBS and SME CLOs are still not competitive funding sources for many lenders in Spain and Italy, despite a sharp spread tightening over the past two years. Given its significance before the financial downturn as a funding source for lending to consumers and corporations, we

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

believe that the securitization market could play an important role in the post-crisis economic recovery. As noted above, securitization is once again financing a substantial proportion of new loans in some countries and sectors. However, further recovery of the securitization market will likely hinge on several factors, including a recovery in underlying credit demand; withdrawal of official sector funding support from the financial system; the development of bank "bail-in" proposals; and, perhaps most importantly, the ultimate shape of regulation directed at securitization investors.

The Weak Economy Is Depressing Loan Growth


Sluggish economic growth continues to depress both supply and demand for lending in Europe. Although economic indicators have turned more positive in the past few monthswith the eurozone exiting recession in Q2 2013, and some high-frequency indicators such as purchasing managers' indices pointing to further growththe recovery will likely remain slow, in our view. We still expect overall eurozone output for 2013 to be down on 2012 in real terms, with only 0.8% growth in 2014. Consumer and business confidence is only slowly recovering, holding back loan demand: According to the European Central Bank (ECB), in Q2 2013 eurozone banks continued to report a net decline in demand for consumer and housing loans, and for corporate credita trend banks expected to continue in the third quarter. Meanwhile, higher regulatory capital requirements and weak asset prices are acting as disincentives for bank lending in the short term. While banks have made significant progress in boosting capital ratios, the European Banking Authority estimated that in December 2012, a sample of 170 European banks needed an extra 95 billion to meet the minimum 7% common equity tier 1 capital ratio requirement. The ECB will reportedly run another stringent stress test in 2014, which could lead to renewed calls for more capital. We expect that the bank deleveraging process may take several more years in some countries. Depressed asset prices in some sectorsnotably, for both residential and commercial real estate in many countriesare further reducing banks' incentives to lend. Loan growth in Europe therefore remains slow, reducing banks' requirements for new funding, including securitizations. Eurozone banks' 12-month net lending to households and non-financial companies in Europe has been negative since mid-2012, with some non-core countries seeing a steeper and more prolonged contraction (see chart 5). Generally weaker economic growth in peripheral Europe, along with higher asset and sovereign default risks, are also partly responsible for wider secondary market spreads on securitizations in those countries, rendering investor-placed issuance uneconomical in many cases. While we see scope for increased net lending in 2014, we expect any rise to be small. In those countries with contracting economies, net bank lending could remain negative in the short term.

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 5

Official Support For The Banking Sector Has Provided Cheaper Funding Alternatives To Securitization
Government and central bank measures to support European financial institutions since the downturn have also diminished investor-placed securitization issuance, in our view. The ECB's three-year long-term refinancing operations (LTROs), launched in December 2011 and February 2012, provided banks with funding at an interest rate equal to the average ECB main refinancing rate over the loan termfar less than many eurozone lenders would pay for private sector funding. Banks borrowed more than 1 trillion through the operations, likely prefunding a large proportion of their future financing needs. While lenders have already paid back a significant amount of the borrowing, outstanding LTRO usage remains elevated on a historical basis, and almost 400 billion higher than in early 2011, before the three-year LTROs (see chart 6).

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 6

Similarly, in 2012, the U.K. Treasury and the Bank of England introduced the Funding for Lending Scheme (FLS). The original scheme allowed lenders to draw down borrowing from the bank between August 2012 and January 2014 for a fee as low as 25 basis points per year, if their net lending to the real economy was positive over the period. The Bank has since extended the FLS by a year, and provided additional incentives for SME lending (see "The Funding For Lending Scheme Extension Could Keep U.K. Securitization Issuance Depressed," published on April 25, 2013). This cheap alternative funding source is likely partly responsible for the sharp decline in U.K. securitization issuance this year. For example, U.K. RMBS investor-placements reached only 4 billion in the first three quarters of 2013, compared with 21 billion over the same period in 2012. We anticipate that FLS funding will still compete with private sector funding through 2014 for most lenders that are growing their balance sheetsdespite the sharp decline in wholesale funding costs since 2012. When these schemes end, many European banks may increasingly use private-sector wholesale funding sourcesincluding securitization.

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

New "Bail In" Rules Could Lead Banks To Rely More On Secured Funding
European Union legislative authorities are still agreeing an upcoming framework for resolving failing banks, while reducing taxpayers' exposure to losses. However, the European Council's proposal in June 2013 on the terms of the Bank Recovery and Resolution Directive suggests that national authorities would have the right to write down or convert to equity (or "bail in") the claims of unsecured creditors of a failing bank. Furthermore, retail and SME depositswhether benefitting from deposit-guarantee schemes or notcould rank higher than unsecured creditor claims if the bank becomes insolvent. By contrast, secured liabilities would be excluded from bail-in. This directive, in its current form, could therefore make senior unsecured bank issuance less economical for issuers, if investors begin to demand higher returns to compensate for the greater risk of loss. This could drive a medium- to long-term shift toward secured funding sourcesincluding securitization and covered bondsalthough senior unsecured placements have remained fairly steady as a proportion of new wholesale funding issuance over the past couple of years (see chart 7). That said, regulatory concerns about asset encumbrance could also lead to a maximum limit on secured issuance in the long term.
Chart 7

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The Stigma Surrounding Securitization Is Starting To Fade, But Regulatory Treatment Remains Harsh
Harsh treatment of securitizations in proposed global and European capital regulations for banks, insurers, and pension funds remains a key stumbling block to the market's eventual recovery, in our view. Under the December 2012 Basel Committee on Banking Supervision consultation on revisions to its securitization framework, the capital charge that banks would incur for holding a securitization exposure is generally much higher than the capital charge they would incur for holding all the underlying collateral without the benefit of credit enhancement (see "S&P's Response To Consultation On Basel Securitization Framework," published on March 19, 2013). Capital charges for senior securitizations under draft Solvency II rules for insurers are up to 10 times higher than those on covered bonds of similar credit quality, and potential future regulation for pension funds may treat securitizations the same way (see "Solvency II Could Push European Insurers Away From Securitizations," published on Dec. 10, 2012). Given that banks, insurers, and pension funds comprise more than half of the European securitization investor base, the long-term future of the market will depend in part on the ultimate shape of these regulations. Upcoming Basel III liquidity rules may also disincentivize banks from holding securitizations. While some RMBS now look set to count as liquid assets under the January 2013 draft of the Liquidity Coverage Ratio (LCR) rules, they can account for at most 15% of a bank's high-quality liquid assets, and are subject to a 25% haircut. By contrast, highly-rated covered bonds, for example, can make up 40% of liquid assets, and incur only a 15% haircut. Under the Net Stable Funding Ratio (NSFR) draft guidelines, securitization holdings require 100% stable funding; highly-rated covered bonds require only 20%. Meanwhile, recent regulatory proposals affecting European CLO managers could stymie the sector's ability to continue funding corporates, in our view. In May 2013, the EBA proposed that, under the Capital Requirements Regulation which will become effective in January 2014, the CLO manager would have to hold a 5% interest in the transaction to prevent bank investors from incurring high capital charges. Some managers of post-crisis CLOs had instead sought to comply with risk-retention guidelines by placing 5% of the transaction with a third-party investor that played a part in the management or selection of the portfolio and committed not to sell or hedge the exposure. For some CLO managers with a limited balance sheet, the 5% retention requirement may be onerous, in our opinion. The relatively poor credit performance of some U.S. structured finance asset classes in recent years has likely influenced the formulation of these rules, in our view. Admittedly, some securitizations with exposure to the U.S. sub-prime housing marketboth RMBS, and collateralized debt obligations (CDOs) backed by RMBShave seen high losses since 2007. However, we note that the credit performance of most other securitization asset classes globally has generally remained in line with our expectations (see chart 8). In Europe, less than 1.5% of structured finance securities outstanding in mid-2007 had defaulted by the end of Q1 2013 (see "Transition Study: Less Than 1.5% Of European Structured Finance Has Defaulted Since Mid-2007," published on June 11, 2013).

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 8

However, there are indications that the stigma surrounding securitization is starting to fade in Europe. In March 2013, the European Commission endorsed "simple securitisation products based on clear and unleveraged structures" in its green paper on long-term financing for the real economy. In April, the International Monetary Fund said that current Solvency II regulatory capital proposals rendered securitizations uneconomical for insurers to hold, and called for a "realistic risk-based assessment" of capital requirements. The ECB recently echoed this sentiment, acknowledging concerns that proposed securitization capital charges for European banks, insurers, and pension funds "may not sufficiently differentiate between high-quality and low-quality products and do not accurately consider ABSs' own historical performance". More tangibly, in July, the ECB reduced rating requirements and haircuts for some securitizations that are used as Eurosystem collateral, and is working with the European Commission and European Investment Bank on a joint project supporting SME CLO issuance as a way to fund lending to small businesses. Last year, the European Commission asked the European insurance regulator to review whether the current draft of Solvency II would depress insurers' investment in key asset classes. In May 2013, the Commission also postponed the implementation of capital rules for pension funds, citing the results of a preliminary quantitative impact study.

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

So, while it seems clear that there is an increasingly positive sentiment among certain European policymakers toward so-called "responsible securitization", it remains to be seen how the final implementation of various regulatory initiatives will reflect this potentially shifting mood.

Post-Crisis Demand For Securitizations Is StrongFor Now


Some portion of the European securitization investor base that existed before the financial downturn has not returned. Structured investment vehicles (SIVs) and securities arbitrage asset-backed commercial paper (ABCP) conduits, for example, may have comprised up to 20% of pre-crisis investment, according to a Barclays Capital estimate. Sponsors have since unwound most SIVs, and the outstanding balance of securitizations backing European ABCP conduits that we rate fell by almost 90% in the five years to February 2013. However, demand from some other investor bases has picked up over the past few years. For example, relatively low spreads on domestic issuance has increasingly led U.S. investors to look to Europe: About 25% of European investor-placed issuance in 2011 and 2012 was U.S.-dollar denominated. Some U.K. RMBS originators have also turned to other countries, with a few tranches denominated in Japanese yen and Australian dollars in 2012. This, coupled with relatively scarce supply, has seen spreads decline sharply across virtually all securitization asset classes since 2009 (see chart 9).

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens

Chart 9

This has kept securitization on the table as a viable funding source for some issuers. If spreads continue to fall, other sectors that have so far not featured in the modest post-crisis recoveryfor example, those collateralized by assets in southern Europecould also gradually return, in our view. And, as European economies begin to recover, increasing lending volumes to consumers and corporates could, all else being equal, lift securitization volumes too. However, this outcome depends on the attractiveness of the asset class for issuers and investors. In the short term, central bank lending is providing an alternative funding source for banks, but sooner or later, lenders will have to fund themselves without recourse to public sector assistance. When that happens, the securitization market's future will likely hinge on its eventual regulatory treatment, in our view.

Related Research
Underwriting The Recovery: Ongoing Bank Deleveraging Constrains Credit Availability Across Much Of Western Europe, June 28, 2013 Transition Study: Less Than 1.5% of European Structured Finance Has Defaulted Since Mid-2007, June 11, 2013 Q&A On The Future Of Solvency II: Pragmatism Is Likely To Prevail, May 15, 2013 The Funding For Lending Scheme Extension Could Keep U.K. Securitization Issuance Depressed, April 25, 2013

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Underwriting The Recovery: European Securitization Could Fund More Lending, If The Regulatory Stance Softens Underwriting The Recovery: Europe's Mid-Market Seeks New Ways To Fund Growth, April 22, 2013 Underwriting The Recovery: Financing The Path Back To Growth In Europe, April 10, 2013 Underwriting The Recovery: Internal Financing And Financial Discipline Keep European Companies On An Even Keel, April 10, 2013 S&P's Response To Consultation On Basel Securitization Framework, March 19, 2013 Solvency II Could Push European Insurers Away From Securitizations, Dec. 10, 2012
Additional Contact: Structured Finance Europe; StructuredFinanceEurope@standardandpoors.com

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