Rating Rationale
April 26, 2022 | Mumbai
 
India Endowment Policy Trust
(Originator: India Endowment Policy Trust)
Rating reaffirmed at 'Provisional CRISIL AAA (SO) '
 
Rating Action
Tranche Name Amount Rated (Rs in Crores) Outstanding Amount Balance Tenure Ratings/Credit Opinions Rating Action
Class A PTC& 20.0^ 20.0 216* Provisional CRISIL AAA (SO)@ Reaffirmed

& Paid-up premium and vested bonus is to be paid to Class A PTC holders by the legal final maturity. The vested bonus is already declared and fixed. Future bonus can be variable and is linked to bonus rates Life Insurance Corporation of India (LIC) declares on a yearly basis
*Indicates door to door tenure which would vary depending on the tenure of the underlying policies
^This is the maximum maturity value that can be expected to accrue to the Class A PTC notes after accounting for paid up premium, future premium payments, vested bonus already declared and future bonus that could be declared by LIC

@ prefix of 'Provisional' indicates that the rating centrally factors in the strength of specific structures, and is contingent upon occurrence of certain steps or execution of certain documents by the issuer, as applicable, without which the rating would either have been different or not assigned ab initio. This is in compliance with a May 6, 2015 directive ‘Standardizing the term, rating symbol, and manner of disclosure with regards to conditional/ provisional/ in-principle ratings assigned by credit rating agencies' by Securities and Exchange Board of India (SEBI) and April 27, 2021 circular ‘Standardizing and Strengthening Policies on Provisional Rating by Credit Rating Agencies (CRAs) for Debt Instruments’ respectively by SEBI.

1 crore = 10 million
Refer to annexure for Details of Instruments & Bank Facilities

Detailed Rationale

CRISIL Ratings has reaffirmed its ‘Provisional CRISIL AAA (SO)’ rating on the Class A pass-through certificate (PTC) notes to be issued by ‘India Endowment Policy Trust’.

 

The trust is yet to issue instruments under this transaction, pending completion of the ongoing dematerialisation process for Class A PTC notes. As on date, premium payments under all schemes assigned to the trust have been made to Life Insurance Corporation of India (LIC) on a timely basis. CRISIL Ratings will continue to monitor developments with regard to the execution of legal documents, listing, and issuance of instruments under this transaction on an ongoing basis.

 

Analytical Approach

This securitisation transaction is backed by assigned endowment and money back insurance policies, originally issued by LIC. The rating is based on the credit profile of LIC, LIC’s claim processing capabilities, the payment mechanism and soundness of the transaction’s legal structure.

 

The transaction envisages issuance of Class A PTC notes under a master trust structure, where these notes would be backed by assigned LIC policies. Each Class A PTC note would be allocated certain assigned policies by the trust, under the master trust programme. The insurance policies, backing the issued notes, are not fungible and cannot be cross utilised. The investor in these notes would continue to pay premiums for the allocated insurance policies. Either upon maturity of these policies or in an unfortunate event of death of the original insured, the claim proceeds from LIC would be used to repay the investors. The transaction provides a tail period of 2 months: difference between the legal final maturity of the issued Class A notes and the maturity of the last LIC policy allocated to the notes. The trust currently houses 154 endowment and money back policies, using which the Class A PTC notes would be issued. The stated 154 policies have been operational for at least 3 years. For policies which are lapsed, no premiums will be payable till the date of encashment. 

 

The Class A PTC notes are entitled to receive the paid-up premium and bonus declared up to the maturity of the underlying policies. The future bonus payments to be made by LIC are variable and are expected to be declared by LIC on a yearly basis. A lower bonus rate in the future can result in lower value accrual to the Class A PTC notes and thus the due amount to the Class A PTC notes is linked to future bonus yet to be declared by LIC. Class A PTC notes investors’ decision to surrender the underlying insurance policies, a delay in receipt of death claims from LIC or a refused or reduced death claim due to unnatural death or other reasons are among the operational issues which can impact the corpus available to make payments to investors in Class A PTC notes; these aspects are not covered by the rating.

Key Rating Drivers & Detailed Description

The following aspects provide support to the transaction and have been factored in by CRISIL Ratings in its ratings analysis:

 

  • Insurance policies by LIC, the public-sector insurer and a dominant player in the Indian life insurance space.
  • Strong credit profile of LIC which benefits from ownership by Government of India
  • Payment mechanism and transaction structure
  • Supreme Court judgement explicitly allowing assignment of life insurance policies
  • Tail period of 2 months
  • The assignment of the LIC policies to the trust is absolute and cannot be reassigned

Liquidity : Strong

The underlying policies are issued by LIC, which is the largest insurer in India with a strong credit profile and maintains substantial liquid investments.

Rating Sensitivity factors

Upward

  • For Class A PTCs: None.

 

Downward

  • Deterioration in credit profile of LIC
  • Non-adherence to transaction structure and terms as well as payment mechanism envisaged at the time of the rating

Additional disclosures for Provisional ratings:

The provisional rating is contingent upon execution of the following documents:

  • Trust deed
  • Legal opinion
  • Trustee’s awareness letter 

 

Additional documents executed for the transaction, if any, should also be provided. The provisional rating shall be converted into a final rating after receipt of transaction documents duly executed within 90 days from the date of issuance of the instrument.

 

The final rating assigned post conversion shall be consistent with the available documents. In case of non-receipt of the duly executed transaction documents within the above-mentioned timelines, the rating committee of CRISIL Ratings may grant an extension of up to another 90 days for the conversion to a final rating.

 

Rating that would have been assigned in absence of the pending steps/ documentation:

In the absence of documentation considered while assigning provisional rating as mentioned above, it is likely that CRISIL Ratings would not have assigned any rating.

 

Risks associated with provisional nature of credit rating:

A prefix of 'Provisional' to the rating symbol indicates that the rating is contingent upon occurrence of certain steps and / or execution of certain documents by the issuer / originator / settlor, as applicable. In case the documents received and/or completion of steps deviate significantly from the expectations, CRISIL Ratings may take an appropriate action including placing the rating on watch or a rating/outlook change. In the absence of the documentation / pending steps, the rating on the instrument is not likely to have been assigned ab initio.

About the Pool

The pool consists 154 endowment and money-back policies issued by Life Insurance Company of India and assigned to India Endowment Policy Trust by the original insured. The details of these policies are as follows:

  • Paid up premium: Rs. 6.49 crores
  • Additional premium to be paid: Rs. 3.10 crores
  • Vested bonus already declared: Rs. 4.48 crores

 

Rating Assumptions

CRISIL Ratings has analysed the legal opinion provided for assignment of policies, non-fungibility of the underlying policies across the Class A PTC notes and bankruptcy remoteness of the trust.

 

If a Class A PTC notes investor surrenders the underlying policy/policies: the surrender value is calculated using the LIC provided surrender value grid. Typically, the surrender value will be considerably lower than the minimum assured maturity value (paid up premium + vested bonus). Occurrence of this event is not covered by the assigned rating as the decision of surrendering the LIC Policies is taken by the Class A PTC note investor. Additionally, the rating doesn’t cover operational issues like a delay in receipt of death claim from LIC or a refused / reduced death claim due to unnatural death or other reasons. For the delay in settlement beyond the specified period of 120 days, the LIC is expected to pay penal interest as per IRDA guidelines

 

CRISIL Ratings has also factored in the following developments in the event of their occurrence:

 

  • Future premiums are not paid for underlying policies: if a Class A PTC notes investor stops paying future premium at any point in time, then the death claim benefit is no longer valid and only the minimum assured maturity value will be paid at maturity.
  • An event of death happens and is reported on time: An amount equal to the sum assured and vested bonus is paid by LIC in case of death of the original insured and the same getting reported to LIC on time. Residual death proceeds from LIC will be paid to the kin of original insured after repaying the Class A PTC investors.
  • An event of death happens and is not reported on time: An amount equal to sum assured and vested bonus as on date of death is paid. The premiums paid by the investor post date of death of the original insured are returned to the Class A PTC notes investor. Residual death proceeds from LIC will be paid to the kin of original insured after repaying the Class A PTC investors.

 

Counterparty details

Capacity

Counterparty Name

Counterparty Rating/ Track record

Effect on credit ratings in case of non-performance

Settlor

ACESO

Unrated

 

No effect envisaged.

 

Collection & Payout Account Bank

ICICI Bank Limited

Rated ‘CRISIL AAA/CRISIL AA+/Stable

Negligible effect. Account bank can be changed without impacting the rating.

Servicer & Trustee

Amicorp Trustees (India) Private Limited

Adequate track record

Negligible effect. Can be replaced at minimal cost.

 

About the Settlor

ACESO is the settlor in this transaction. The company is a market maker company in India, providing solutions to LIC Policy holders to monetize their policies. ACESO and its associate companies have facilitated in monetizing endowment policies worth over Rs. 250 Million. ACESO has secondary insurance policy management servicing capabilities to administer and manage policies. It was incorporated in the year 2018 and is managed by a group of professionals who have been in this business for nearly 2 decades. ACESO is an associate company of Goldstar Group having multiple business interest in Gold Jewellery, Diamonds, IT solutions, Real estate, Financing through a duly registered non-banking financial company (NBFC), Dravya Finance Pvt Ltd. Key management personnel at ACESO are: Mr. Ketan B Mehta (Promoter Director, Chartered Accountant), Mr Alkesh Shah (Promoter Director, also a Promoter and Vice Chairman of Goldstar Jewellery Ltd) and Mr. Himanshu Ashar (Promoter, Chartered Accountant).

Key Financial Indicators

Particulars

Unit

Mar-22

2021

Total assets

Rs crore

N/A

N/A

Total income

Rs crore

N/A

N/A

Profit after tax

Rs crore

N/A

N/A

Gross NPA (90+ dpd)

%

N/A

N/A

Adjusted gearing

Times

N/A

N/A

Return on managed assets

%

N/A

N/A

*ACESO is the settlor in this transaction and in case of its non-performance no effect is envisaged on the credit rating of the proposed transaction.

Any other information: Not applicable

Note on complexity levels of the rated instrument:
CRISIL Ratings' complexity levels are assigned to various types of financial instruments. The CRISIL Ratings' complexity levels are available on www.crisil.com/complexity-levels. Users are advised to refer to the CRISIL Ratings' 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 Cr.)

Date of

Allotment

Maturity Date*

Complexity level

Assigned

Rating

Class A PTCs

20.00^

To be placed

Up to 216 months

Highly Complex

Provisional CRISIL AAA (SO)

*Indicates door to door tenure and would vary depending on the tenure of the underlying policies

^This is the maximum maturity value that is expected to accrue to the Class A PTC holders after accounting for paid up premium, future premium payments, vested bonus already declared and future bonus that could be declared by LIC

Annexure - Rating History for last 3 Years
  Current 2022 (History) 2021  2020  2019  Start of 2019
Instrument Type Outstanding Amount Rating Date Rating Date Rating Date Rating Date Rating Rating
Class A PTC LT 20.0 Provisional CRISIL AAA (SO)   -- 28-10-21 Provisional CRISIL AAA (SO)   --   -- --
All amounts are in Rs.Cr.
Criteria Details
Links to related criteria
Legal analysis in structured finance transactions
CRISILs rating methodology for ABS transactions
Evaluating risks in securitisation transactions - A primer

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