Rating Rationale
January 25, 2021 | Mumbai
INDIAN RECEIVABLE PGDA DEC19 C
(Originator: Tata Motors Finance Limited)
Rating continues on 'Watch Developing'
 
Rating Action
Tranche NameAmount Rated (Rs in Crores)Outstanding AmountBalance TenureCredit Collateral (Rs.)Ratings/Credit OpinionsRating Action
Acquirer payouts459.91158.241320.25CRISIL A (SO) /Watch DevelopingContinues on 'Rating Watch with Developing Implications' "&"
& Equivalent
* After January 2020 payouts
# Indicates door to door tenure from pool cut-off date. Actual tenure will depend on the level of prepayments in the pool, extension due to moratorium and exercise of the clean-up call option
1 crore = 10 million
Refer to annexure for Details of Instruments & Bank Facilities

Detailed Rationale

CRISIL Ratings credit opinion of ‘CRISIL A (SO)’ Equivalent on acquirer payouts under INDIAN RECEIVABLE PGDA DEC19 C continues on 'Rating Watch with Developing Implications'. The payouts are backed by a pool of vehicle loan receivables originated by Tata Motors Finance Limited (TMFL; 'CRISIL AA-/CRISIL A/Negative/CRISIL A1+'). 

 

The rating action was initially driven by administrative delays at the end of the assignee bank (which is also the bank where cash collateral (CC) is maintained in the form of fixed deposit) in utilising CE.

 

Consequently, CRISIL had placed the transaction on ‘Rating Watch with Developing Implications’. Link

 

However, in April 2020 payout, CC was utilised to the extent of shortfall up to March 2020 payouts and transaction waterfall was followed. For April 2020 – August 2020 collection, in accordance with RBI’s COVID-19 package, investor had provided consent for moratorium and subsequently for any shortfall CC was not utilised.

 

In October 2020 payout, adjustment was made to the billing on account of advance/part prepayment collected for the period March 2020 – August 2020 from contracts that were under moratorium. The collection for September 2020 was sufficient to pay investor after adjustment of advance/ part prepayment and replenish CC (partial).

 

In November and December 2020 payouts, the structure was adhered to and CC was utilised to pay any shortfall in the assignee payout. Adjustments were made to billing for collections from contracts under moratorium. The collections from the contracts under moratorium have been treated as advances and the billing of these contracts in the subsequent months have been covered to the extent of the advance payments made.

 

In the end of December 2020, TMFL had exercised buy-back of identified contracts from the pool at the request of the investor, as per clause agreed initially in deed of assignment. However, timelines for which had been delayed due to lockdown on account of COVID-19.

 

For contracts which should have matured in 2020 as per schedule, but had opted for moratorium, the tenure could not be extended due to operational challenges. Therefore, payment has been made to the investor, to the extent of future receivables of these contracts, by utilising CC in January 2021 payout. Post this, the outstanding CC amount stands reduced to 20.25 (Rs Crore).

 

CRISIL will monitor the adjustments in billing and collection from these contracts over the next few months and the watch will be resolved based on the steady collection.

 

The credit opinion factors in credit quality of pool cash flows backing the payouts, TMFL's origination and servicing capabilities and the credit enhancement available in the transaction structure. 

 
As per the transaction structure, the originator has assigned 95% of the par value of the loan receivables to the assignee in exchange for a purchase consideration equal to 95% of the pool principal outstanding at the time of assignment. The assignee is promised interest payouts and principal payouts on a monthly basis, and CC is to be utilised on payout dates to bridge any shortfall in assignee payouts.

 
The transaction has been evaluated as part of Partial Credit Guarantee (PCG) scheme offered by Government of India to Public Sector Banks (PSBs) for purchase of pooled assets from NBCFs/HFCs through DA route. The credit opinion does not factor in the partial credit guarantee of the Government of India to the transaction and is purely based on the credit collateral as provided by the originator in the structure.

Key Rating Drivers & Detailed Description

Strengths:

  • Credit support available in the structure
    • Credit-cum-liquidity collateral, after January 2021 payout, of Rs 20.25 crore (12.2% of future payouts) provides support exclusively to acquirer’s payouts. As per the terms of the transaction, the credit-cum-liquidity collateral shall not be used to fund any shortfall in the seller’s payouts.

Weakness:

  • No internal subordination
    • As per the terms of the transaction there is no credit support from the pool in the form of subordinated excess interest spread (EIS) or principal over-collateralization.

 

CRISIL has adequately factored these aspects in its rating analysis

Liquidity: Strong

  • Liquidity is strong given that the credit enhancement available in the structure is sufficient to cover losses exceeding 1.2 times the currently estimated base shortfalls

Rating Sensitivity factors

Upward factors

  • Credit enhancement  (based on both internal and external credit enhancements) available in the structure exceeding 2.0 times the estimated base case shortfalls on the residual cash flows of the pool.
  • A sharp upgrade in the rating of the servicer/originator

Downward factors

  • Credit enhancement falling below 1.5 times the estimated base case shortfalls
  • A sharp downgrade in the rating of the servicer/originator

About the Pool

The pool consists of vehicle loan contracts comprising mostly of commercial vehicles. After January 2021 payout, the weighted average seasoning of the pool was 36.4 months, and the pool is geographically diverse, with the top three states accounting for 35.9% of the pool principal, with a weighted average loan-to-value ratio of 95.1% and average ticket size of Rs. 14.3 lakhs.

 

Key Rating Assumptions

To assess the base case collection shortfalls for the transaction CRISIL has analysed vintage-wise static pool performance of loans disbursed across asset classes, excluding the ones disbursed under subvention or loss cover schemes. This analysis has been done for originations by TMFL from FY 2012 to FY2018 with performance up to March 2019. Also, CRISIL has considered contracts that are current on payment as of 6 months seasoning, as contracts in the securitised pool exhibit a similar repayment and seasoning profile. Performance of rated securitisation transactions, as well as the performance of TMFL's portfolio has also been considered. 90+ dpd on TMFL's portfolio was 5.0% as of June 2019.

CRISIL's has adequately factored all these pool specific characteristics and analysed the bucket wise shortfall of the loans in the pool to arrive at the base case shortfall.

  • CRISIL has assumed a stressed monthly prepayment rate of 0.3% to 0.8% in its analysis.
  • CRISIL does not envisage any risk arising on account of commingling of cash flows since CRISIL's short term rating on the servicer is 'CRISIL A1+'.
  • CRISIL has adequately factored in the risks arising on account of counterparties (refer to counterparty details below).
  • CRISIL has run sensitivities based on various shortfall curves (front-ended, back-ended and normal) and has adequately factored the same in its analysis

 

Counterparty Details

 

Capacity

Counterparty Name

Counterparty Rating / Track record

Effect on credit ratings in case of non-performance

Originator and seller

TMFL

‘CRISIL A/CRISIL AA-/Negative/CRISIL A1+’

No effect.

Servicer

TMFL

‘CRISIL A/CRISIL AA-/Negative/CRISIL A1+’

Significant effect, because of change in servicing quality and replacement cost of servicer (not factored in by CRISIL). However, CRISIL does not envisage the requirement for replacement.

Collection and Payout Account Bank

Bank of Baroda

 

 

Credit-cum-liquidity collateral in the form of Fixed deposit

TMFL

‘CRISIL A/AA-/Negative/CRISIL A1+’

Significant effect; as the credit opinion on acquirer payouts is linked to long term credit risk profile of the credit enhancement provider.

Acquirer’s representative

ITSL

Adequate track record

Negligible effect. Can be replaced at minimal cost

 

About the Originator

In March 2016, TMFHL acquired 100% stake in TMFL (earlier Sheba Properties Ltd), a non-banking finance company registered with RBI, for Rs 405 crore from TML. As on March 31, 2016, TMFL had total assets of Rs 205 crore, of which the investment portfolio constituted 94% of the assets or Rs 193 crore.

 

With the implementation of the scheme of arrangement effective January 2017, the entire new vehicle finance business has been transferred from TMFHL to TMFL. Post transfer, TMFL is a non-deposit taking, systemically important, non-banking financial and asset financing company and will be one of the major financiers of CVs and cars for TML's customers and channel partners. In fiscal 2020, the company reported profit after tax (PAT) of Rs 59 crore on total income (net of interest expenses) of Rs 1,372 crore (basis Indian Accounting Standards), as against a net profit of Rs 204 crore (net of interest expenses) and total income of Rs 1,208 crore in the previous fiscal.

 

Past Rated Pools

CRISIL have ratings outstanding on 7 securitisation transactions originated by TMFL. CRISIL is receiving monthly performance related to all the TMFL transactions

Key Financial Indicators

As on /for the  year ended March 31, 

 

2020

2019

Total assets

Rs crore

31,744

32,917

Total income (net of interest expenses)

Rs crore

1,372

1208

Profit after tax (PAT)

Rs crore

59

204

PAT including other comprehensive income

Rs crore

89

209

Total capital ratio

%

16.85

15.25

Gross NPA

%

5.89

2.92

Net NPA

%

5.10

1.52

 

Any other information: Not applicable

Note on complexity levels of the rated instrument:
CRISIL complexity levels are assigned to various types of financial instruments. The CRISIL complexity levels are available on www.crisil.com/complexity-levels. Users are advised to refer to the CRISIL complexity levels for instruments that they consider for investment. Users may also call the Customer Service Helpdesk with queries on specific instruments.

Annexure - Details of Instrument(s)

Type of Instrument

Rated Amount

(Rs Crore)

Date of Allotment

Maturity date#

Coupon Rate (p.a.p.m.) (%)

Outstanding

Rating/Credit Opinion &

Complexity Level

Credit cum liquidity Enhancement

(Rs Crore)

Acquirer’s payouts

459.91

31-Dec-19

10-Feb-22

9.10%

CRISIL A (SO) Equivalent/Watch Developing

 

Highly Complex

40.56

1 crore = 10 million

# Indicates door-to-door tenure; actual tenure will depend on the level of prepayments in the pool, exercise of clean-up call option, extension due to moratorium and the extent of shortfalls

&Acquirer payouts holders are entitled to receive timely interest and timely principal on a monthly basis

Annexure - Rating History for last 3 Years
  Current 2021 (History) 2020  2019  2018  Start of 2018
Instrument Type Outstanding Amount Rating Date Rating Date Rating Date Rating Date Rating Rating
Acquirer payouts LT 158.24 CRISIL A (SO) Equivalent/Watch Developing   -- 27-10-20 CRISIL A (SO) Equivalent/Watch Developing   --   -- --
      --   -- 22-04-20 CRISIL A (SO) Equivalent/Watch Developing   --   -- --
      --   -- 09-01-20 CRISIL A (SO) Equivalent   --   -- --
      --   -- 08-01-20 Provisional CRISIL A (SO) Equivalent   --   -- --
All amounts are in Rs.Cr.
 
 
Links to related criteria
CRISILs rating methodology for ABS transactions
Evaluating risks in securitisation transactions - A primer
Legal analysis in structured finance transactions

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