UK Residential Mortgage Loan Analysis Criteria: Credit
Transcription
UK Residential Mortgage Loan Analysis Criteria: Credit
toronto new york chicago london paris frankfurt Methodology U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation november 2007 contact information Elisa Malavasi Vice President Structured Finance Quantitative Group Tel. +44 (0)20 7562 5609 emalavasi@dbrs.com Victoria Johnstone Senior Vice President Structured Finance Quantitative Group Tel. +44 (0)20 7562 5608 vjohnstone@dbrs.com Kai Gilkes Managing Director Structured Finance Quantitative Group Tel. +44 (0)20 7562 5606 kgilkes@dbrs.com Apea Koranteng Managing Director Structured Finance EMEA Tel. +44 (0)20 7562 5603 akoranteng@dbrs.com DBRS is a full-service credit rating agency established in 1976. Privately owned and operated without affiliation to any financial institution, DBRS is respected for its independent, third-party evaluations of corporate and government issues, spanning North America, Europe and Asia. DBRS’s extensive coverage of securitizations and structured finance transactions solidifies our standing as a leading provider of comprehensive, in-depth credit analysis. All DBRS ratings and research are available in hard-copy format and electronically on Bloomberg and at DBRS.com, our lead delivery tool for organized, Web-based, up-to-the-minute information. We remain committed to continuously refining our expertise in the analysis of credit quality and are dedicated to maintaining objective and credible opinions within the global financial marketplace. U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation TABLE OF CONTENTS Introduction Credit Analysis Prepayment Analysis Loan Aggregation Analysis Advantages of Approach 5 5 5 5 6 Part 1: U.K. Residential Mortgage Default Criteria The Benchmark Two-Year PD Estimate The Base Case Two-Year PD Estimate Credit Risk Band CCJs and/or Bankruptcies or IVAs Loan-to-Value (LTV) Employment and Other Income-Related Variables Right-to-Buy (RTB) Loan Purpose Repayment Type Loan Term Loan Size Second Lien Loan Product Buy-to-Let (BTL) Credit Risk Layering The Base Case Lifetime PD Estimate Portfolio Default Rate Distribution Rating-Specific Portfolio Default Rates 8 9 9 11 11 12 13 15 15 16 17 17 17 17 18 22 22 24 27 Part 2: U.K. Residential Mortgage Loss Criteria LGD Overview Components of LGD Principal Amount Owed (Exposure at Default, or EAD) Current Property Value Sale Price of the Foreclosed Property Costs Prior Ranking Loans LGD per Rating Level Foreclosure MVDs per Rating Level Loan-Level and Portfolio-Level LGD Calculations 28 28 28 28 28 31 35 36 36 36 36 Part 3: U.K. Residential Mortgage Prepayment Criteria 38 Part 4: U.K. Residential Mortgage Loan Aggregation Criteria 42 Concluding Remarks 43 Appendix A: The DBRS U.K. Residential Mortgage Loan Analysis Model 44 Appendix B: The DBRS U.K. Mortgage Loan Analysis Model Example Tear Sheet 45 Appendix C: Loan-level Example Computations of Lifetime PD, LGD and EL 48 Appendix D: The DBRS U.K. Mortgage Loan Analysis Model Example Rep Lines 50 3 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Introduction This report describes the DBRS loan analysis methodology for U.K. residential mortgage portfolios and forms part of the DBRS criteria for rating U.K. residential mortgage-backed securities (RMBS) and other transactions linked to residential mortgage assets denominated in the United Kingdom. This methodology describes the approach to three main areas that DBRS considers to require a loan-level analysis: credit, prepayment and loan aggregation. CREDIT ANALYSIS The DBRS mortgage credit quality assessment addresses the principal amount of a portfolio that could be potentially lost in different rating scenarios. As such, it forms an integral part of the analysis used to assess the credit enhancement required to maintain a rating on a RMBS tranche. Principal loss on a mortgage loan occurs when the borrower fails to pay back the full balance of the outstanding loan amount. There are two key components to this analysis. First, DBRS estimates a loan’s probability of default (PD); that is, how likely it is that the borrower will stop paying the mortgage loan and the lender will be forced to foreclose and sell the property. Second, the analysis assesses how much the lender will lose if the property is subject to foreclosure and a forced sale (the loss given default, or LGD), as the lender may not be able to re-coup the full outstanding loan balance from the sale proceeds. The product of the PD and LGD for a loan gives the expected principal loss (EL) for that loan. As such, the DBRS credit analysis establishes PD and LGD estimates (and therefore EL) on a loan-by-loan basis and for the portfolio as a whole over different rating scenarios. DBRS assumes that a B rating corresponds to a benign economic environment and is representative of the status of the U.K. housing market economy over the last two to five years. A detailed analysis of the behaviour of U.K mortgage loans over this time therefore forms the basis of the DBRS base case, or B rating scenario. The impact of deterioration in the economy on portfolio PD and LGD levels is then assessed to obtain these estimates at higher rating levels, which are representative of more stressful economic scenarios. For non-synthetic mortgage-backed transactions, the portfolio PD and LGD then become inputs for the subsequent cash flow analysis. Cash flow simulations overlay the assumed portfolio PDs and LGDs (along with other economic stresses such as interest rates and prepayments) within the transaction structure to assess the ability of the rated notes to withstand economic stress and, as such, maintain a rating. PREPAYMENT ANALYSIS The DBRS mortgage prepayment analysis assesses the loan characteristics known to influence prepayment rates. The outputs of a loan-level assessment are aggregated to create a base case prepayment assumption for the portfolio. The prepayment assessment addresses the amount of unscheduled principal received over time, and as such, is an important consideration within a cash flow analysis, both from note life, and tranche rating strength perspectives. The assumed prepayment rate has a large influence on the amount of excess spread (typically used to cover principal losses in most U.K. transactions), and therefore is a key factor in the assessment of the ability of a tranche to withstand a rating stress. Given its importance, DBRS considers a loan-level prepayment model as crucial in understanding the dynamics of the transaction through time, and accurately assign a rating. LOAN AGGREGATION ANALYSIS DBRS produces standardised loan aggregation “rep lines” for each transaction, with aggregation based on characteristics that influence the repayment profile of the loans (e.g., interest-only periods, interest rate types, remaining term). As such, the rep lines act as a transparent overview of the asset cash flow profile, and also allow for efficient and accurate cash flow modelling. 5 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 ADVANTAGES OF APPROACH The DBRS U.K. residential mortgage loan analysis methodology provides an enhanced method of assessing credit and prepayment risk, along with the production of standardised rep lines. The criteria used to calculate these components are described in full in the following methodology. There are a number of key benefits to the approach, highlighted below. • The DBRS U.K. Residential Mortgage Loan Analysis Model is a Microsoft Excel-based tool used by DBRS to analyse the credit quality of U.K. loan portfolios using the methodology described in this report. In addition, the model also outputs a DBRS base case prepayment vector, and rep lines that are subsequently used in any cash flow modelling. The model is available in open format and free of charge as part of DBRS’s aim to increase transparency in the rating process and allow market participants to fully understand how risk is assessed. For information on how to gain access to the model, please see Appendix A. An illustration of some key outputs of the model is given in Appendix B. • The DBRS credit and prepayment assumptions stem from a comprehensive review and assessment of several data sources that covered the specifics of the U.K. residential mortgage market. Outputs from loan-level analyses, where available, have been integrated with results from portfolio-level breakdowns of existing transactions. Particular attention has been given to observed historical performance in order to estimate base case performance and provide a benchmark to estimate mortgage behaviour under more stressful economic conditions. • The approach allows for predictive base case PDs and LGDs to be estimated at the loan and portfolio levels over both a two-year period and lifetime horizon. This base case performance is assumed to represent a specific rating scenario; namely, B. DBRS considers that accurate base case performance estimates are extremely important for a number of reasons. (1) Within the Basel II framework, more lenders may be motivated to move lower rated and equity tranches off their balance sheets. As such, the ability of investors to access a detailed risk assessment of the EL under base case conditions over a range of time periods is crucial. (2) DBRS believes that deal surveillance can be significantly enhanced by being able to measure and track deal performance over time with respect to an initial base case expectation identified to represent a specific rating level. This means that DBRS can easily match actual deal performance with rating expectations and provide accurate and timely rating implications. • DBRS strongly believes that the behaviour of foreclosed property values is dramatically different from the average values obtained from a generic house price index. There is strong evidence both on the portfolio and loan levels that despite dramatic house price increases in recent times, foreclosed properties suffer significant market value declines, which may have been underestimated in alternative approaches. • The methodology has been created so that it can easily incorporate external credit bureau scores should they become accessible to third parties. DBRS considers that the inclusion of such scores within a default model can add considerable predictive power and hence allow for better differentiation of risk across mortgage portfolios. Therefore, a methodology that can easily integrate these scores is crucial to making full and timely use of their added value. • There are meaningful default adjustments to loans that are seasoned or in arrears that can facilitate more accurate portfolio default estimates through time. This ensures that the methodology can be reliably used not only at the pre-bond issuance stage (or for the initial assessment of portfolio purchases), but also integrated into the surveillance process. 6 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 • Portfolio modelling techniques are used to create a distribution of potential portfolio default rates. There are two main benefits to such an approach: (1) Rating-specific default rates can be directly determined from the portfolio default distribution by holding the distribution to a “rating standard” implied by the DBRS Corporate Default Table. This is quite different from an methodology that multiplies base case estimates by rating multiples. The portfolio approach also allows for a consistent quantitative approach across different asset classes. For example, collateralised debt obligation (CDO) asset portfolios are also held to the same standard. (2) A distribution of portfolio default rates will allow users to test transactions over a wide range of PDs (and matched LGDs) in a stochastic framework, which may complement the usual deterministic approach (where tranches are tested with discrete rating-specific default scenarios). Although DBRS intends to initially use a deterministic approach to test U.K. RMBS tranches, a stochastic approach in creating more insights into RMBS tranche performance is a key area of ongoing research. • The DBRS methodology maximizes the advantages of obtaining loan-level information, and extends its use to enhance other assumptions within the rating approach. (1) Prepayments – given the large impact prepayment assumptions have on note life and excess spread, accurate and refined estimates of prepayments are crucial for transaction transparency, efficiency and robustness. DBRS is the first rating agency in Europe to create (and make available on a transparent basis) a loan-level approach to prepayment modelling. (2) Loan Aggregation – the creation of standardised rep lines allows rating analysts to quickly and easily identify key cash flow risks within the asset pool (such as unhedged positions and discount reserve sizings). This rep line creation also allows efficient cash flow modelling, without any compromises in performance. In the present report, the computation of the two credit estimates (PD and LGD) are addressed separately in the first two sections. The third section covers the DBRS approach to the loan-level prepayment estimations, and the fourth section describes the loan aggregation methodology. 7 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Part 1: U.K. Residential Mortgage Default Criteria This section describes the DBRS methodology used to calculate loan-level PDs and portfolio-level default rates for U.K. residential mortgage portfolios. One important component of this methodology is an approach to calculate base case two-year and lifetime PD estimates for individual mortgage loans. The approach also includes the creation of a portfolio default distribution, which allows for the extension to rating-specific portfolio default rates. A summary of the methodology used to calculate loan-level PDs and portfolio default rates is given below and described in detail in the following pages. The same benchmark two-year PD estimate is assigned to each loan. A base case two-year PD estimate is calculated for each loan by adjusting the benchmark two-year PD to account for individual risk characteristics associated with each loan. A base case lifetime PD estimate is calculated for each loan by extending the base case two-year PD to account for individual loan seasoning. A portfolio default rate distribution is calculated by means of a “single factor” model that requires the weighted average of the base case lifetime PDs and an asset correlation estimate. Rating-specific portfolio default rates are calculated by holding the portfolio default distribution to a “rating standard,” as implied by the DBRS Corporate Default Table. 8 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 THE BENCHMARK TWO-YEAR PD ESTIMATE Each loan in the mortgage portfolio is initially assigned the same benchmark two-year PD. Benchmark performance has been calibrated from U.K. loan-level and portfolio-level mortgage credit behaviour over the past four to five years, from approximately 2002 to 2006. This period represents a benign economic environment for mortgage performance (e.g., low interest rates, low levels of unemployment, strong house price growth), and consequently this period has been associated with low arrears and mortgage default rates (see Figure 1.1). The benchmark PD assigned to all loans is 0.125%.1 This is aligned with the two-year estimate from repossession data shown in Figure 1.1 and will be adjusted upward or downward on a loan-by-loan basis depending on the individual loan characteristics (see the following section). Figure 1.1: Mortgage Arrears and Repossession Rates in the United Kingdom 2.00% 1.75% 1.50% 1.25% 1.00% 0.75% 0.50% 0.25% 0.00% H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 % of mortgage loans outstanding 2.25% 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Time Source: CML statistics. Repossessions 6-12m arrears 12m+ arrears The benchmark loan PD was calculated over a two-year time period for a number of reasons. Firstly, this time period allowed for an increased number of analysis points over a range of loan seasonings, across the four- to five-year horizon chosen to represent benchmark performance. Secondly, DBRS intends to include credit bureau scores (in the event they become available for third-party use2) to help assess the credit risk of mortgage loans. Generic credit scores created by the bureaus active in the United Kingdom (e.g., Experian, Equifax and Call Credit) are highly predictive measures of default and are extensively used by a range of mortgage and other lenders. The scores (e.g., Delphi, Risk Navigator and CallScore) summarize borrower credit history and condense many relevant performance factors (e.g., borrower behaviour on all credit lines, level of indebtedness, geographic default data) into a single numeric value. Since credit bureau scores are commonly calibrated to reflect performance over a one- or two-year period, DBRS has developed a methodology that can easily incorporate the scores if they are made available. DBRS is a strong supporter of use of any measures that aid in predicting adverse trends at a granular level, especially where there is a prospect of a deteriorating credit cycle. THE BASE CASE TWO-YEAR PD ESTIMATE The benchmark two-year PD of 0.125% is then adjusted on a loan-by-loan basis to create the base case two-year PD estimate per loan. These adjustments are to account for borrower, property and loan product factors that increase or decrease the credit risk associated with a particular loan. An overview of the risk-adjustment factors used is provided in this section. 1. For other jurisdictions, DBRS will look to local market conditions to derive benchmark loan performance. In addition, adjustments to the benchmark to create loan-level PDs will also be jurisdiction-dependent. 2. At the time of publication, the use of bureau information by third parties is prevented by the Principles of Reciprocity developed by the Steering Committee on Reciprocity (SCOR), the governing body of the bureau databases. Changes to the Principles of Reciprocity to allow for third-party use of the data and scores under certain circumstances is, however, currently under consideration by SCOR. 9 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 A more qualitative evaluation of underwriting standards, credit policies and servicing practices is then overlaid on the estimated loan-level PDs to adjust for servicer- or originator-specific influences on loan credit performance. Further adjustments may also be necessary in the case of significant concentration risks. The following section focuses on the loan, borrower and property characteristics that DBRS considers to be influential on a borrower’s propensity to default. The default behaviour of each mortgage loan in the pool is forecast by integrating past credit performance information with additional characteristics that may influence a borrower’s likelihood of default. Each characteristic is associated with a multiplicative factor that adjusts the 0.125% benchmark PD up or down. Table 1.1 summarizes each characteristic and gives the associated multiple used to adjust the benchmark PD. The influence of each characteristic on default is then discussed on the following pages. A worked example of this analysis for a single loan is given in Appendix C. Table 1.1: Loan-level Risk Adjustments 10 Risk Characteristic Characteristic Value Base Multiple Credit Risk Band A B C D E n/a 1.00 2.00 4.00 8.00 Adverse Credit History CCJs <= GBP 100 GBP 100 < CCJs <= GBP 2,000 GBP 2,000 < CCJs <= GBP 5,000 CCJs > GBP 5,000 Prior Bankruptcy/IVA 1.00 2.45 2.80 3.55 3.55 Loan-to-Value (LTV) <=40 50 60 70 80 90 95 100 0.60 0.80 1.00 1.30 1.65 2.10 2.35 2.65 Employment/Income Self-Certified (Employed) Self-Certified (Self-Employed) Fast Track Loan-To-Income (LTI) >3.5 Single Income Self Employed 1.75 1.35 1.10 1.25 1.25 1.15 Buy-to-Let (Stabilised ICR) <=100 105 110 115 120 125 130 2.00 1.80 1.65 1.45 1.30 1.15 1.00 Right to Buy Yes 1.10 Purpose Debt/Equity Re-mortgage 1.25 Repayment Type IO 1.35 Term Repayment Loan >25 yrs 1.20 Loan Size Jumbo (Region Specific) 1.10 2nd Lien 2nd Ranking Loan 1.50 Loan Product Tracker (For Life with Teaser) Tracker (Short Term) Discount (Short Term) Fixed (Short Term) 1.05 1.05 1.05 1.10 Risk Layers LTV >= 95% & Self Cert/High LTI LTV >= 90% & Past CCJs/Bankrupt LTV >= 90% & Past CCJs/Bankrupt & Self Cert/High LTI 1.35 1.75 1.85 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Credit Risk Band In order to differentiate between the credit quality of borrowers, each loan is assigned to a credit risk band, based on past credit performance information. Credit risk bands range from “A” to “E,” with “A” borrowers considered to be the least risky and “E” borrowers having severe current or past credit problems. As discussed, the best summary of past credit performance information is contained within external credit bureau scores such as those provided by Experian, Equifax and Call Credit, which use a variety of information sources to identify credit risk (e.g., payment behaviour across all borrower credit lines, credit-to-debt measures, length of history, etc.). It is DBRS’s preference to determine credit risk bands from external bureau scores. In the absence of such scores being available, DBRS uses the existing credit information provided to assign credit risk bands. This information is a much reduced subset of that contained within a bureau score, and as such DBRS will not assign an “A” grade to any loan on the basis of this information. The available information currently used by DBRS to determine the credit risk band is the following: • Combined amount (and age) of past County Court Judgments (CCJs). • Any prior bankruptcy or individual voluntary arrangement (IVA). • Current arrears on mortgage. Credit risk bands are assigned according to the matrix shown in Table 1.2. In addition, the credit risk band is adjusted downward by a category if the borrower has at least one CCJ that is less than one year old. Table 1.2: Cedit Risk Band Assignment Amount of CCJs Months in Arrears 0 1-3 4-5 6+ CCJs <= GBP 100 B C D E GBP 100 < CCJs <= GBP 2,000 C D E E GBP 2,000 < CCJs <= GBP 5,000 D E E E CCJs > GBP 5,000 and/or Prior Bankruptcy/IVA E E E E CCJs and/or Bankruptcies or IVAs Adverse credit history is a key differentiator for default risk because individuals who have suffered debt problems in the past have a higher propensity for arrears and defaults on future debt repayment. Significant previous financial difficulties are indicated by arrears or defaults on loans, CCJs or insolvency. The range of mortgage products targeting this specific segment of the residential mortgage market is generally referred to as sub-prime. Growth in the number of people with credit problems, as well as an increased demand for debt consolidation products, has boosted the U.K. sub-prime mortgage market. Lending to borrowers with adverse credit history implies higher default risk compared with mainstream lending and is evidenced by significantly higher mortgage arrears and default performance of the subprime compared with the prime mortgage market. A recent study by the Council of Mortgage Lenders (CML)3 concludes that the more severe the level of credit adversity, the worse the performance. In the United Kingdom, CCJs are legal decisions deliberated by the County Courts with regards to monetary sums. A CCJ is recorded on a borrower’s credit report every time a loan repayment is not made within specified times and/or conditions, and the creditor of the balance due brings the case to court. Unless the CCJ is paid off within 30 days of being registered, it is likely it will remain on the credit file for six years, thus significantly affecting a borrower’s credit status. More severe instances of CCJs are associated with repeated patterns of credit difficulties by a borrower, hence the DBRS multiple relating to the CCJ characteristic increases as the amount of CCJs rises. 3. Council of Mortgage Lenders (CML). “Adverse Credit Mortgages,” November 2006. 11 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Individuals in severe financial difficulties may declare an insolvency status in order to settle and clear outstanding debts. In the United Kingdom, this is typically achieved by either bankruptcy or IVA. A bankruptcy is ordered by a court and results in a public legal declaration stating the inability of an individual to repay his or her creditors. Any debt that is unable to be covered by available (or, sometimes, future) assets is then discharged. A bankruptcy order can restrict borrowers on their future employment possibilities (e.g., prevent an individual from holding public office). As an alternative to bankruptcy, an IVA is a privately arranged plan for the repayment of debts to creditors and as such is not presided over by a court. An IVA is generally associated with a lower cost than a bankruptcy, is confidential and has no restrictions in terms of future employment. As such, consumer debtors are increasingly turning to IVAs in order to avoid bankruptcy (see Figure 1.2). Figure 1.2: Number of Individual Insolvencies in the United Kingdom 20,000 18,000 16,000 Number 14,000 12,000 10,000 8,000 6,000 4,000 1998 1999 2000 2001 2002 2003 2004 2005 2006 Q1 Q2 P Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q4 Q1 Q3 Q2 Q1 Q4 Q3 Q2 Q4 Q1 Q3 Q2 Q1 Q4 Q3 Q2 Q4 Q1 Q3 Q2 0 Q1 2,000 2007 Time P = Provisional. Source: The Insolvency Service statistics. Bankruptcies IVAs DBRS does not discriminate between bankruptcies and IVAs in terms of risk adjustments because they are both viewed as an indicator of severe financial distress. Loan-to-Value (LTV) LTV is the ratio between the principal balance on the mortgage and the appraised value of the property serving as security for the loan itself. The input used by DBRS in the default model is the current LTV at the time of securitization. This is calculated by summing all of the outstanding balances from every loan secured by the same property (e.g., first-lien and second-ranking mortgages) and dividing the total by an estimate of the current market value of the property. The current market value is calculated by taking the given valuation and adjusting, if necessary. Adjustments are made on the basis of the property valuation method and the last valuation. Details of these adjustments are given in the LGD part of the methodology. In the case of flexible loans, the maximum drawable amount is taken into account instead of the outstanding loan balance. Higher LTV ratios are associated with increases in the likelihood of default, attributable to the progressively smaller portion of equity that the borrower has in the property. Equity is the difference between the value of the property and the amount of all loans secured against it. The smaller the equity, the smaller the potential financial benefit the borrower can retain from the property, and the lower the incentive to maintain loan repayments. 12 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 DBRS has approximated the relationship between LTV and the likelihood of default by the function shown in Figure 1.3. Here, the multiple applied to the benchmark loan PD rate increases as LTV increases. Note that for LTVs below 60%, this multiple is less than 1.0, indicating a decrease in overall PD compared with the benchmark. The highest multiple is 3.0 once the LTV reaches 105%. Also note that static values reported in Table 1.1 on page 9 show examples of this function at various LTV levels. Figure 1.3: Multiple to Benchmark PD by Current LTV 3.5 3.0 Base Multiple 2.5 2.0 1.5 1.0 0.5 115% 110% 105% 100% 95% 90% 85% 80% 75% 70% 65% 60% 55% 50% 45% 40% 35% 30% 0.0 Current LTV Employment and Other Income-Related Variables Borrower propensity to default is clearly related to the ability to make timely mortgage repayments on an ongoing basis. DBRS regards affordability and other income- and employment-related aspects as very important, particularly at a time when numerous affordability product innovations have taken place in the U.K. market. In addition to this, U.K. consumer indebtedness levels have grown substantially in recent years, raising serious concerns as to the ability of people to repay their debts should the current favourable economic and housing conditions deteriorate. The following sections outline employment and other income-related features that DBRS considers to affect performance behaviour. These features are for owner-occupied properties only and do not apply to buy-to-let (BTL) products, which are discussed separately in a following section. Self-Certification Self-certification is used by borrowers who want to obtain a mortgage without having to demonstrate their earnings to a standard required by conventional mortgage underwriting criteria. Here, applicants simply declare their own income, without having to provide the lender with any underlying documentation (e.g., pay slips, audited accounts). Typically, borrowers who seek to self-certify are self-employed, commission-based or contract workers. Self-employed borrowers may choose to self-certify for a number of reasons. Firstly, most lenders require self-employed workers to provide two to three years of audited financial accounts, meaning that more recent self-employed borrowers would be unable to satisfy this request. Secondly, audited accounts and/or current tax returns are often time lagged and may not show the latest figures of a borrower’s income. Thirdly, self-employed borrowers may also perceive that supplying the necessary documentation would be too onerous and time-consuming. Commissionbased workers may also choose to self-certify, as they receive a salary with a high proportion of bonus payments and hence show a large degree of variability in income over time. Contract workers and those with incomes from a variety of sources choose to self-certify because their total earnings may not otherwise be considered under a traditional mortgage. 13 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 There are additional risks with self-certified mortgages, and the concept that a self-certified borrower could not afford the loan under normal lending criteria is a common one. Recent Financial Services Authority (FSA) research4 has highlighted that lenders generally have a higher level of material arrears for their self-certified business compared to mainstream lending. Lenders endeavor to offset this risk by a variety of ways, the most common being: – Most self-certified mortgage providers pass the applicant’s stated income through a plausibility check to ensure their stated job type fits within a reasonable salary range. – More conservative credit scoring cuts are taken into account when assessing self-certified mortgage applications, as well as lower LTV ratios so as to deter borrowers from taking out a mortgage that they cannot afford. – Fraud detection systems across U.K. lenders also discourage systematic fraud in the self-certified market (e.g., CIFAS – the U.K.’s Fraud Prevention Service, which pools information on financial crime). Despite these additional safeguards, the higher level of arrears experienced with this product type means that DBRS considers self-certified loans to be more risky than benchmark loans. Note that DBRS considers self-certification products to employed borrowers more risky than those to self-employed borrowers, given that a self-employed borrower may have a more “legitimate” reason for self-certification (such as the burden of supplying audited financial accounts). Fast Track Some lenders are currently providing an accelerated approval process for low-risk borrowers that speeds up the time they take to finalise a mortgage offer. This process, known as Fast Track, enables lenders to have the right to seek full income verification for a loan application, even if they eventually choose not to do so in practice. Lenders generally offset the risk involved in offering Fast Track loans by making these products available only to LTVs lower than a certain limit, typically 85%. Given that the lender can seek to fully verify a borrower’s income in the approval process, the likelihood of borrowers overenhancing their stated earnings is lower compared with self-certificated incomes. This is reflected in a significant differentiation of the base multiples for the Fast Track versus the Self-Certification product types. Self-Employed Self-employed borrowers who do not self-certify their income need to provide the mortgage lender with documentary evidence of their earnings (e.g., latest tax payments). However, compared with borrowers who are employees, self-employed borrowers tend to have lower stability in terms of monthly income. In addition, self-employed borrowers often need to undertake large financial investments in order to set up their own business, which may make then more vulnerable in an increasingly stressful financial environment. Loan-to-Income (LTI) LTI is a measure of loan affordability and is commonly used by lenders to determine how much they are prepared to advance on a mortgage. LTI is calculated by dividing the loan balance by the total income for the household (e.g., the sum of incomes in the case of multiple borrowers). Many lenders also use more sophisticated affordability measures to take into account other financial commitments (e.g., council tax, unsecured loan repayments, childcare costs, utility bills, etc.), but usually in conjunction with LTI measures. In a recent report, the CML indicated that approximately 85% of U.K. lenders continue to use LTI measures (either as a sole determinant of the maximum loan amount or as a crosscheck to the affordability measure).5 Although it is likely that more complex affordability measures are better indicators of risk than a simple LTI, the components of these measures are not consistent across lenders. As such, DBRS considers LTI a simple but effective means of assessing affordability. 14 4. Financial Services Authority (FSA). “FSA Finds Improvements from Lenders but Mixed Results for Brokers in SelfCertified Mortgages,” 14 November 2005. 5. Council of Mortgage Lenders (CML). “U.K. Mortgage Underwriting,” April 2006. U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 In the past, loans were generally restricted to 3.0 times a single income or 2.5 times joint incomes. Recently, lenders have generally started to increase income multiples, sometimes up to 4.0 or even 5.0 times their earnings, for borrowers with low LTVs or good credit history. Higher LTI ratios are a sign of greater financial commitment and make a borrower more susceptible to default in case of life changes such as divorce and unemployment. As a consequence, DBRS applies a risk adjustment to LTIs that exceed 3.5. Single Income When mortgage repayments are serviced by two separate incomes, if one income becomes unavailable (e.g., as a result of unemployment), being able to rely on a co-borrower’s income mitigates the likelihood of default. As such, the repayments on a mortgage serviced by a single income attract a multiple to the benchmark PD rate. Right-to-Buy (RTB) The RTB scheme was originally introduced in the United Kingdom in 1980. Under the scheme, council tenants and tenants of registered social landlords or housing associations can buy their own homes at a low price, because part of the rent paid over the previous years of tenancy is discounted from the full market value. Borrowers who exercise their RTB typically have more fragile economic backgrounds and are likely to have relied on some form of financial support in the past. As owner-occupiers, however, these borrowers do not receive any additional housing benefit to assist them with their mortgage repayment. For this reason, DBRS considers loans granted on the basis of this scheme as riskier compared with standard mortgage loans. Loan Purpose Borrowers apply for mortgages primarily for two reasons: home purchase or re-mortgage. As seen in Figure 1.4, re-mortgage activity in the United Kingdom has boomed over the last years. % of mortgage originations Figure 1.4: Distribution of Gross Mortgage Lending by Loan Purpose 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Time Home Purchase Re-mortgage Other* Source: CML statistics. * Includes lifetime mortgages, further advances and buy-to-let. Typically, when borrowers re-mortgage, they use the proceeds from the re-mortgage to pay down an already existing mortgage, with the same property being used as security. The main motivation for this type of re-mortgage, also referred to as refinancing, is usually to take advantage of a more favourable interest rate offered by an alternative mortgage provider. Over the last years, strong house price appreciation persuaded many borrowers to re-mortgage in order to release equity from their property. As such, a growing proportion of borrowers are raising capital from their properties, hence taking on more debt. Debt consolidation is a particular form of equity release re-mortgaging, where one loan (e.g., the re-mortgage) is taken to pay off other debts already existing (e.g., unsecured loans, credit lines, etc.). 15 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 DBRS considers only raising capital and debt consolidation to be associated with a higher likelihood of default compared with traditional mortgages. Being a form for increasing credit exposure, they contribute to stretch borrowers’ finances, potentially compromising their ability to repay their debts. Repayment Type There are currently two main mortgage repayment methods in the United Kingdom: repayment and interest-only (IO), although there are many variations of each of these two types (e.g., a mixture of the two, where an IO reverts to repayment after a certain time period, investment backed, etc.). In a standard repayment mortgage, both interest and some of the capital borrowed is paid back over time to ensure the mortgage is totally paid off by the end of the term. In contrast, IO mortgages only require the repayment of the interest on the initial principal balance until maturity, when the borrower repays the principal balance. There is a general trend toward the growing use of IO or mixed mortgage products that allow borrowers to defer the payment of principal (see Figure 1.5). There are a number of possible reasons for this. Firstly, mortgage originators recognize that IO mortgages can service borrowers who require more flexibility in the way they repay their mortgages. For example, those who have fairly low earnings but expectations for extra financial income (e.g., bonuses) can benefit from smaller regular payments of interest and a more flexible approach to repaying the principal. Secondly, IO mortgages may be becoming more popular as they require a smaller short-term monthly commitment than a regular repayment. With growing levels of unsecured consumer indebtedness, combined with high house prices, borrowers may consider IO loans as a way to afford property that they may not be able to afford with a regular repayment scheme. Figure 1.5: Distribution of Mortgage Originations by Repayment Method % of mortgage originations 79.0% 71.5% 67.0% 64.8% 28.5% 28.2% 22.2% 16.0% 2004 6.7% 6.3% 5.0% 2005 2006 4.8% 2007 Time Capital And Interest Interest-Only Mixed Source: CML statistics. As such, DBRS has some concern that IO borrowers are more likely to have stretched financial circumstances (although certainly this is not necessarily the case). In addition, there are further concerns around borrowers’ ability to pay back the entire balance due on the mortgage at the maturity date. In the past, IO loans were usually combined with regular payments to some sort of vehicle to ensure the repayment of principal at loan maturity. The Financial Services Authority (FSA) recently highlighted, however, that many IO borrowers did not have a strategy in place for repaying the capital. Although borrowers can refinance at maturity, the market environment at that future date is unknown and, as such, exposes borrowers to refinance risk. 16 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Loan Term Traditionally, the maximum term offered by U.K. mortgage originators was 25 years. Although rare, mortgage lenders recently have extended possible mortgage terms for some products, sometimes up to 40 years. DBRS regards repayment mortgages with a final maturity greater than 25 years as riskier compared with shorter amortizing products. There is a general concern that a borrower may choose a long amortization term in order to reduce his or her monthly payments and, as with IO products, could be indicative of some financial vulnerability. Loan Size Given that mortgage providers generally limit the maximum loan size based on income multiples, larger loan amounts are only available to borrowers with higher incomes. DBRS regards larger loans (jumbo loans) as riskier than smaller loans. The rationale behind this view is that higher incomes are subject to greater volatility in the event of an economic downturn. Typically, these borrowers are more likely to rely on significant bonuses and may find it difficult to maintain their financial status when forced to move to a new job position (as the result of a changing economic environment). In order to account for the variety of economical environments across the United Kingdom, DBRS defines jumbo loan limits based on region and on the time of origination (see Table 1.3). Table 1.3: Example Jumbo Loan Limits (GBP) for Different Regions and Origination Time Periods Region Q2, 2006 Q4, 2006 Q2, 2007 Greater London 430,000 460,000 500,000 South East 360,000 375,000 405,000 Nth Ireland 255,000 320,000 385,000 South West 320,000 330,000 355,000 East Anglia 290,000 305,000 320,000 West Midlands 280,000 280,000 295,000 East Midlands 260,000 265,000 275,000 Wales 250,000 260,000 270,000 North West 250,000 255,000 265,000 Yorkshire & Humberside 245,000 250,000 260,000 North 230,000 235,000 250,000 Scotland 215,000 225,000 245,000 Second Lien A second-lien mortgage is a subordinated loan taken on a property already used as security for an existing mortgage. Lien positions differentiate levels of subordination in the rights of creditors to receive proceeds from the sale of the mortgaged property in the event of borrower default. Second-lien mortgages, although a common feature of many mortgage finance products in continental Europe, are less widespread in the United Kingdom. In the United Kingdom, second-lien mortgages are generally taken out as an equity release tool for raising capital or to finance the down payment of a purchase. Secondlien loans are potentially granted to borrowers who are unable to re-mortgage easily to release equity and, as such, may represent a more risky profile than the benchmark. Loan Product DBRS has reviewed the increasing variety of interest rate products that are currently available for residential mortgages in the United Kingdom. A brief summary of the most common product types are given below: • Standard Variable Rate (SVR) is set by the individual lender and usually increases and decreases in line with the Bank of England’s base rate. Hence, mortgage interest payments based on SVR are likely to rise or fall every time the Bank of England modifies the base rate. 17 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 • Tracker (For Life) loans are guaranteed to track the rate set by the Bank of England plus a differential. This differential remains constant over the entire life of the loan (e.g., the Bank of England’s base rate +0.55%). Mortgage interest payments will rise and fall with base rate changes. • Tracker (For Life with Teaser) loan products track the rate set by the Bank of England plus or minus a differential for an initial period. This differential then increases at a point in the future and then stays constant for the remaining term of the loan (e.g., the Bank of England’s base rate +0.19% for the first two years, then increasing to base rate +0.67% for the remaining life). Mortgage interest payments will rise and fall with base rate changes, but there will be a definite increase in mortgage payments once the teaser period expires. • Tracker (Short Term) loan products track the rate set by the Bank of England plus or minus a differential for a short term (commonly between two and five years) and then switch to the SVR for the remaining life of the loan. Mortgage interest payments will rise and fall with base rate changes, but there will be a definite increase in mortgage payments once the Tracker period expires (SVR is typically set above the Tracker rate). • Discount (Short Term) loan products pay interest on the basis of the SVR minus a discount for a short term (commonly between two and five years) and then switch to the SVR for the remaining loan term. Mortgage interest payments will rise and fall with base rate changes, but there will be a definite increase in mortgage payments once the discount period expires. • Fixed-Rate (Short-Term) loan products pay interest based on a fixed interest rate (at a rate typically below the SVR) for a short term (commonly between two and five years) and then switch to the SVR for the remaining term. Here, the initial interest payments in the fixed-rate period will not rise and fall with base rate changes, and borrowers may be exposed to an increase in mortgage payments when they revert to the SVR. The relative amount of this increase is unknown at the time of loan origination. DBRS has applied risk adjustments to loan products where there is the potential risk of payment shock (a sharp increase in regular mortgage payments as a result of a change in the interest rate on the loan). Loans that track the ongoing changes in interest rates over time (e.g., SVR, Full Term Tracker) are not subject to this risk adjustment. Loans that generally track the ongoing changes in interest rates over time but are subject to an increase in payments once the mortgage product reverts to a higher rate are, however, considered to have some exposure to payment shock (e.g., Tracker (For Life with Teaser), Tracker (Short Term), Discount (Short Term) loan products). Fixed Rate (Short Term) loan products are seen to have to most potential for significant payment shock, as they do not adjust with increases in the base rate. If interest rates increase during the fixed period, the borrowers become exposed to a substantial increase in their regular mortgage payments at the time of the switch to the SVR. Buy-to-Let (BTL) A BTL mortgage is for the purchase or re-mortgage of a residential property used for investment purposes. Here, the property is let to tenants as opposed to direct occupation by the borrower. In the United Kingdom, BTL lending has experienced spectacular growth since the late 1990s, as shown in Figure 1.6, and corresponds to almost 10% of all U.K. outstanding mortgages. 18 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 120,000 12% 100,000 10% 80,000 8% 60,000 6% 40,000 4% 20,000 2% 0 % of mortgage loans outstanding £m of mortgage loans outstanding Figure 1.6: Outstanding Buy-to-Let Mortgages in the United Kingdom (£m and % total value) 0% H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 H2 H1 1999 1999 2000 2000 2001 2002 2002 2002 2003 2003 2004 2004 2005 2005 2006 2006 2007 Time Mtgs outstanding at end period (% total value) – RHS Mtgs outstanding at end period (£m) – LHS Source: CML statistics relating to new specialist lenders (e.g., Paragon Mortgages, Mortgage Express), hence not taking into account mortgages to investors from mainstream lenders. The expansion of the BTL market is attributable to several key drivers. Residential property investors have been encouraged by strong house price appreciation and good rental demand.6 In tandem, BTL lending has expanded significantly over the last few years, and a growing number of lenders offer bespoke BTL products at an attractive price. Growing volumes, however, have been accompanied by a growing number of BLT arrears and repossessions. DBRS considers that this increase has been potentially driven by a number of factors: • A decrease in the minimum required interest coverage ratio (ICR), which is computed as the expected monthly rental income divided by the monthly mortgage interest payment (see Figure 1.7). • Higher LTV ratios, mainly as a result of increases in the maximum amount lent to landlords (see Figure 1.7). Figure 1.7: Buy-to-Let Mortgage Trends 140% 0.8% 120% 0.7% 0.6% 100% 0.5% 80% 0.4% 60% 0.3% 40% 0.2% 20% 0.1% 0% 0.0% H1 2002 H2 2002 H1 2003 H2 2003 H1 2004 H2 2004 H1 2005 H2 2005 H1 2006 H2 2006 H1 2007 Time Maximum LTV (LHS) Minimum Interest Coverage Ratio (LHS) 90+ arrears (RHS) Source: CML statistics relating to new specialist lenders (e.g., Paragon Mortgages, Mortgage Express), hence not taking into account mortgages to investors from mainstream lenders. 6. Royal Institute of Chartered Surveyors (RICS). “RICS Residential Letting Survey Great Britain,” July 2006. 19 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 • Rising interest rates. • Changes in the type and experience level of borrowers accessing the residential property market; a growing proportion of new entrants are “amateur” landlords. • An increase in the average aggregate loan ceiling for individual investors, which grew from GBP 1 million in H1 2006, to GBP 1.5 million in H2 2006, and is currently reported to be at around GBP 2.5 million. BTL mortgages are also exposed to the risk that the property may not be tenanted for part of the year, meaning the landlord may need to rely on alternative income to cover the loan repayment. Lenders try to mitigate the above exposure by requiring the rental coverage ratio to exceed 100%, but the surplus rent may not be sufficient to cover long terms without tenancy, as well as other repairs and maintenance costs. DBRS applies a risk adjustment to the benchmark two-year PD for BTL loans based on a DBRS-calculated lowest base case ICR (the “stabilised” ICR). This analysis calculates loan-level ICRs at six-month intervals over a four-year time period from the date of the portfolio assessment. The ICR at each time period is calculated using the following equation: ICR = updated rental income interest payable The initial step in this calculation is to update the given rental income, this is not usually updated through time, and consequently, the rental income for seasoned loans will be out-of-date. DBRS applies two adjustments to the given rental income: a rental increase and a tenant void period. Rental Increase Assumption A rental increase of 3.5% per annum on average has been assumed in order to increase the rental income from origination to a level more likely to reflect a current rental income. The 3.5% annual increase equates to the retail price index (RPI) observed over the last three to four years. This may initially seem like a relatively unsophisticated assumption, given that there will be regional variations in rental increases, and also rental increases may not track the RPI directly, but other data sources corroborate this approximate increase. An initial analysis on a survey of regional rental incomes indicates that since 2003, average rents have increased between approximately 0% and 8% per annum, depending on region. Using the proportion of BTL loans that DBRS has observed within each region, the weightedaverage annual rental increase is calculated at 3%. As such, a 3.5% increase is considered an adequate proxy for a rental increase assumption. Rental Void Assumption A rental void refers to a period in which a property is vacant, and as such, the borrower will not receive any rental income during that period. An average void period of one month per year has been assumed, on the basis of an analysis of reported void data from the Association of Residential Letting Agents (ARLA), shown in Figure 1.8. 20 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 5.0 4.5 4.0 2002 2003 2004 2005 2006 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 Q4 Q3 Q2 Q1 3.0 Q4 3.5 Q3 Number of Weeks Void Per Annum Figure 1.8: UK Buy-To-Let: Average Void Period Per Annum 2007 Time Period (Quarter) Source: The ARLA History of Buy-To-Let Investment 2001 to 2007. The interest payable at each six-month time period is calculated on a dynamic basis, taking into account the actual rate of interest the borrower will pay at that time. For example, if a loan is currently paying on a short-term fixed rate and is due to switch to a BBR tracker in 20 months, for the time periods 0, 6, and 18 months, the interest payable will be calculated from the current fixed interest rate. At the 24 month period, the borrower will have switched products, and as such, the current interest payable will be calculated using a BBR assumption plus the stabilised margin. Any underlying floating rate component (e.g., Libor 3M, BBR) will be assumed to be the rate at the date of the portfolio assessment, and will remain unchanged through the four-year time period. This means that any change in the ICR through time is due to a switch to a different interest rate margin due to the expiration of an initial margin. An example of the interest rates used for each loan product type specified by DBRS is given in Table 1.4. Table 1.4: Interest Payable for ICR Calculation Rate Type Rate Payable Before Swtich Rate Payable After Switch Standard Variable Rate (SVR) Current Floating Rate + Stabilised Margin N/A BBR Tracker (For Life with Teaser) Current BBR + Current Margin Current BBR + Stabilised Margin BBR Tracker (Short Term) Current BBR + Current Margin Current Floating Rate + Stabilised Margin BBR Tracker (For Life) Current BBR + Stabilised Margin N/A Fixed (Short Term) Current Coupon Current Floating Rate/BBR + Stabilised Margin Fixed (For Life) Current Coupon N/A Discount (Short Term) Current Floating Rate + Current Margin Current Floating Rate + Stablised Margin For each loan, DBRS takes the lowest experienced ICR through the four-year time period as the stabilised ICR and makes a BTL risk adjustment on the basis of this ICR. This adjustment is made using the function shown in Figure 1.9. Note that static values reported in Table 1.1 on page 10 show examples of this function at various stabilised ICR levels. 21 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Figure 1.9: Multiple to Benchmark PD by Stabilised ICR 2.25 Base Multiple 2.00 1.75 1.50 1.25 1.00 140% 135% 130% 125% 120% 115% 110% 105% 100% 95% 90% 0.75 Stabilised ICR Although a BTL loan can attract a multiple that increases the PD in comparison with the benchmark PD, note that these types of mortgage loans do not attract the employment or income multiples that are associated with owner-occupied properties. Credit Risk Layering DBRS makes a base case PD adjustment to account for risk layering within a single mortgage loan; that is, the simultaneous presence of multiple risk factors is assumed to have an adverse effect on PD over and above that predicted by the single multiple associated with each component. Credit risk layering has been an important contributor to the rise of arrears and defaults in the U.S. mortgage market in recent times, and although the presence of credit risk layering in the United Kingdom has not been as prevalent as in the United States, DBRS considers this to be an important element in ultimate default behaviour. Simultaneous risk elements include combinations of high LTV (indicating minimal borrower down payments), past credit problems (e.g., past CCJ and/or bankruptcy or IVA), and high LTI ratios and/or self-certification. THE BASE CASE LIFETIME PD ESTIMATE In order to expand the two-year loan PD estimates to “lifetime” expectations, the two-year estimate is extended by means of an assumed cumulative default distribution. The cumulative default curve for mortgages follows a fairly stable pattern over both time and different data sources, with the majority of defaults on a static portfolio occurring by the end of year five (60 months). The assumed cumulative default distribution used to derive lifetime PD estimates is given in Figure 1.10 Note for simplification that the fitted curve has been divided into six- to 12-month segments (this also allows for more stability in the lifetime default estimates over small changes in seasoning). 22 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Figure 1.10: DBRS U.K. Cumulative Default Curve 100% Cumulative % of Defaults 90% 80% 70% 60% 50% 40% 30% 20% 144 138 132 126 120 114 108 102 96 90 84 78 72 66 60 54 48 42 36 30 24 18 6 0 0% 12 10% Time Since Origination In order to calculate the lifetime PD estimate for a single loan, the percentage of cumulative defaults that should have occurred by the number of months the loan is seasoned (the number of months since origination) plus 24 months (the length of time the two-year PD estimate is predicting forward) is derived from the assumed cumulative default distribution shown in Figure 1.8. Consider the following example where a loan is seasoned for six months and has a current two-year PD estimate of 3%. The six-month seasoning plus the 24 months takes the loan to 30 months in the cumulative default curve. Reading from the bar chart plotted in Figure 1.8 on the previous page, the percentage of cumulative default assumed to have occurred by 30 months is 37.5% (note that this percentage will be the same for all loans seasoned between six months and 12 months). This means that the two-year PD estimate of 3% represents 37.5% of the lifetime PD estimate. The two-year PD estimate therefore needs to be multiplied by 100%/37.5% (or 2.67) to get the lifetime PD estimate (3% x 2.67 = 8%). This analysis can also be represented by plotting the implied multiples over loan seasoning instead, shown in Figure 1.11. Figure 1.11: Two-Year Base Case PD Multiple by Loan Seasoning 4.0 Seasoning Multiple 3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0 0 6 12 18 24 30 36 42 48 54 60 66 72 78 84 90 96 102 108 114 120 Time Since Origination 23 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 PORTFOLIO DEFAULT RATE DISTRIBUTION The analysis described in the previous section details the approach used to estimate “lifetime” base case loan-level PDs. These estimates have been developed from U.K. loan- and portfolio-level mortgage credit behaviour from approximately 2002 to 2006 and extended to lifetime PDs using a standardised cumulative default curve. This period is assumed to represent a benign economic environment for mortgage performance, which DBRS assumes to represent a B rating scenario. Under more stressful economic conditions, however, a portfolio will exhibit a higher default rate than the base case, such as the levels of default experienced in the early 1990s. The effect of benign and stressful economic environments on mortgage default rates can be seen in the default time series plotted in Figure 1.12. Figure 1.12: U.K. Annual Mortgage Defaults over Time Annual Mortgage Default Rate More Stressful – high interest rates – high unemployment – house price decline 2006 2005 2004 2003 2002 2001 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 1989 1988 1987 1986 1985 1984 1983 1982 Benign/Base Case – low interest rates – low unemployment – strong house price growth Time Source: CML statistics. DBRS assumes that for a single portfolio of mortgage loans, there is a distribution of potential future portfolio default rates. The default rate that is exhibited by a portfolio is a function of the base case performance and the prevailing economic conditions, as represented in Figure 1.13. As mortgage loans in the United Kingdom have not undergone what could be considered extremely stressful (e.g., AAA) conditions, the full shape of the distribution has clearly not been empirically verified. In addition, given that mortgage portfolios are generally very large (e.g., greater than 1,000 loans), there is generally no need to simulate the default of each loan to create a distribution of defaults. A given loan may or may not default, but with such a large portfolio, the loss incurred by a single loan is negligible, and the primary concern is the overall portfolio default rate. As a consequence, simple analytical models can be used to estimate the portfolio default distribution, in particular the “tail” behaviour of the distribution that extends well beyond historically observed mortgage default rates. Figure 1.13: Example Distribution of Mortgage Portfolio Default Rates Probability Benign/Base Case More Stressful Extremely Stressful Portfolio Default Rate 24 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 The framework used to approximate a distribution of mortgage portfolio default rates is a modified version of the single factor Gaussian credit loss model first proposed by Vasicek (1987).7 This model allows for the creation of a hypothetical distribution of mortgage defaults using two parameters: the mean (or expected) portfolio default rate and the sensitivity of borrowers to changes in the economic environment. The mean of the portfolio default distribution can be assumed to be the weighted average of the base case lifetime PDs.8 The variation in the distribution is determined by a measure of borrower sensitivity to macroeconomic effects. The influence of the economy, despite its complexity (e.g., gross domestic product (GDP), interest rates, unemployment), can be approximated as a single factor that influences borrowers’ propensity to default. Sensitivity to this factor is equivalent to assuming individual mortgage borrower performance is correlated, where the higher the sensitivity, the higher the correlation. For a more technical description of the single factor model framework, please see Vasicek (1987) or Gordy (2003).9 The single factor model approach is very similar to the Basel II methodology for large, well-diversified mortgage portfolios, with one key difference. DBRS assumes that the single factor correlation changes over base case default rates, whereas in the Basel II framework, the correlation remains constant at 15%. Figure 1.12 shows how the correlation changes with the mean portfolio default rate. The correlation is capped at 25% for all portfolios with expected lifetime base case PD below 2%. It then decreases as the mean default rate increases and floors at 10% once the mean portfolio default rate reaches 8%. The decrease in correlation at high default rates can be interpreted as a decrease in the sensitivity of high-PD borrowers to macroeconomic effects relative to low-PD borrowers (i.e., high-PD borrowers are more prone to idiosyncratic (borrower-specific) effects than low-PD borrowers). The result of this correlation “slope” is a decrease in the relative change in default rate a high-PD portfolio would experience under a deteriorating economic environment compared with a low-PD portfolio. Under this assumption, a sub-prime portfolio with a mean default rate of 10% might produce default rates as high as 35% in a particularly stressful economic environment (e.g., a relative change of 3.5 times the mean). Under the same stress scenario, a prime portfolio with a much lower mean default rate of 2% would show a much greater relative increase (e.g., up to 24%, or 12.0 times the mean). The correlation assumptions given in Figure 1.14 have been derived from a number of sources. Firstly, an analysis of U.K. mortgage default rates over time10 reveals estimates in the range of 10% to 30%, depending on the frequency of observation, the time period and the definition of mortgage default. Although this analysis indicates a suitable range of overall mortgage correlation, data was not segmented by risk profile. Therefore, it did not allow an analysis of how mortgage correlation potentially varies with changes in the underlying risk profile of the portfolio. The notion that estimates of correlation decrease over changes in PD is consistent with other studies11 and produces stressed mortgage default rates that are broadly consistent with market expectations. DBRS considers that ongoing research into mortgage correlation estimates extremely important, both from a regulatory and risk-analysis perspective, and will continue to develop its approach in this area. 7. Vasicek, O. (1987). “Probability of Loss on Loan Portfolio.” Working paper, Moody’s KMV. 8. DBRS floors the base case portfolio PD estimate at 1%. In order to continue to rank-order portfolios with very low expected default rates, a scaling factor that decreases as PD increases is applied to all base case portfolio expected default rates below 2%. 9. Gordy, Michael B. (2003). “A Risk-Factor Model Foundation for Ratings-Based Bank Capital Rules,” Journal of Financial Intermediation. 12, pp. 199–232. 10. CML statistics. 11. Board of Governors of the Federal Reserve System. “The Asset-Correlation Parameter in Basel II for Mortgages on Single-Family Residences,” November 2003. Risk Management Association. “Retail Credit Economic Capital Estimation – Best Practices,” February 2003. 25 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Figure 1.14: Assumed Mortgage Asset Correlation 27.5% Assumed Correlation 25.0% 22.5% 20.0% 17.5% 15.0% 12.5% 10.0% 7.5% 5.0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10% Mean Portfolio Default Rate In order to illustrate the output of the single factor model, Figure 1.15 shows an example distribution of portfolio default rates for a portfolio with a mean default rate of 7% and a correlation of 10.5%. Probability Figure 1.15: Example of a Mortgage Portfolio Distribution 0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% Portfolio Default Rate 26 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 RATING-SPECIFIC PORTFOLIO DEFAULT RATES The analysis described in the previous section results in an analytical distribution of potential default rates for the mortgage pool. Given that a DBRS rating ultimately addresses the probability of default of a tranche backed by the mortgage pool, the distribution can be analysed to determine a portfolio default rate that is consistent with a given rating. This is done by determining the probability that a certain default rate will be exceeded and ensuring that this probability is less than or equal to the default probability of a ”benchmark bond. To ensure consistency with portfolio models in other asset classes (e.g., CDOs), the DBRS corporate default table is used as the benchmark. As an example, assume a single “A” benchmark bond has a default probability of 3%. We therefore need to determine the portfolio default rate that has a likelihood of being exceeded that is less than or equal to 3%. Note that this is equivalent to finding the 97th percentile of the default distribution. Using the portfolio distribution given in Figure 1.13, this mortgage default rate is approximately 18% (i.e. the likelihood of exceeding an 18% default rate is considered by DBRS as being “single ‘A’ remote” – Figure 1.16). Probability Figure 1.16: Example of a Mortgage Portfolio Distribution with a single “A” Cut Point 3% of the distribution exceeds the portfolio default rate of 18% 0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% Portfolio Default Rate 27 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Part 2: U.K. Residential Mortgage Loss Criteria This section describes the DBRS methodology used to calculate the loss given default (LGD) for U.K. residential mortgage portfolios. This approach is primarily centred on the potential market value decline a foreclosed property could experience compared with its valuation at the time of portfolio assessment. As such, the DBRS analysis has focused both on foreclosed property values compared with the general market norm and on how they may behave under more stressful conditions. LGD OVERVIEW Upon default, the property is repossessed and sold to recoup the amount owed by the borrower. Upon sale, the amount owed by the borrower does not only include the loan principal balance; there will also be costs associated with the foreclosure process and the forced sale, and given that there is a lag between severe delinquency status and the actual property being sold, the borrower will also owe accrued interest. Note that the LGD calculations described in this report exclude accrued interest, as the primary objective of the DBRS credit analysis is to estimate principal loss only. LGD is calculated by taking the difference between the outstanding principal loan balance owed by the borrower (also known as exposure at default, or EAD) and the recoveries deriving from the sale of the property and any other form of credit mitigation in place (e.g., mortgage insurance payments), net of any costs and prior ranking loans. This difference is then expressed as a percentage of the EAD. LGD = EAD – (property foreclosure sale price – costs – prior ranking loans) EAD In the United Kingdom, most loans are originated with LTVs that are lower than 100%; that is, the loan principal balance advanced is less than the value of the property. Therefore, upon borrower default, the sale proceeds should cover the outstanding loan balance, and losses should be minimal. If the market value is eroded for any reason (property neglect, economic downturn) and repossession and sale costs are netted from recoveries, then more extreme losses will be observed. The decrease in the property value is commonly referred to as a market value decline (MVD) and is clearly a key factor when determining expected losses for mortgage default loans. COMPONENTS OF LGD The DBRS methodology for the estimation of each of the contributing components to LGD (e.g., the amount owed, the costs, the property valuation and the assumed recoveries upon sale) is described in the following pages. A worked example for a single loan is given in Appendix C. Principal Amount Owed (Exposure at Default, or EAD) DBRS expects that loans will default relatively early in their life, with the most default vulnerability occurring between 12 and 48 months. Loans defaulting within this period are unlikely to show significant decreases in the principal amount owed at origination. Loan products that do amortise tend to show minimal decreases in the first years of their life, and there are also many non-amortising products now being originated in the United Kingdom. In addition, although a borrower may manage to pay off more principal balance through partial prepayments, it is less likely that this borrower type will subsequently default. Therefore, DBRS assumes that the principal amount owed at default is the same as the balance at the time of the portfolio assessment (e.g., the date of pool cut). Current Property Value DBRS makes adjustments to the given property valuation on the basis of the property valuation method, and the time since valuation (in order to account for any increase or decrease in the property valuation since the given valuation date). Property Valuation Methods There are a number of methods that are currently used to value properties in the United Kingdom to 28 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 assess their adequacy as security for a mortgage advance. Historically, lenders have relied on a full physical valuation, where a property expert such as a chartered surveyor would visit the property in question. The surveyor valuation is based on the condition of the interior and exterior of the property, in addition to comparative sales in the vicinity and general market activity. Over the last four to five years, however, a number of alternative valuation solutions have evolved. In an increasingly competitive market, these solutions are the result of the pressure lenders are facing to reduce costs and time associated with property valuations. In general, these alternative solutions are restricted to either less risky loan characteristics (such as low LTV loans) or situations where there is a known past physical valuation (e.g., re-mortgages, further advances, equity release). – Drive-by Valuation: A valuer visits the property and assesses it from the property boundary. Comparative sales and market activity also contribute to the final valuation. – Desktop Valuation and Automated Valuation Models (AVMs): In both desktop and AVM valuations, a property is valued without any physical inspection. With a traditional desktop valuation, a house price index or a comparable property evaluation is used to estimate the property value, usually from a past known full property value. A more formalised version of the desktop valuation is derived using an AVM, which assigns a property valuation using a statistical algorithm that can run on an automated basis once certain property characteristics are entered by the user. The AVM derives values based on an analysis of comparable sales in the area and property value indexation (e.g., from repeated sales). The accuracy of an AVM generally depends on the number of suitable comparative properties and the age of their valuations. Therefore, AVM performance is best when the property comes from a densely populated homogenous area with a high number of property sales. This statement is true for all methods of valuation. AVMs, however, are unique in that each valuation produced is accompanied by an independent measure of “confidence.” AVM confidence measures are based on the number, similarity and time of the comparable properties used to calculate the target valuation. The more similar and numerous the comparables are, and the more recent the sales data, the higher the level of certainty that can be associated with the target property valuation. Surveyor, desktop and drive-by valuations have no such measure of accuracy. This, however, does not mean they are immune to the specifics of a particular market, which can make valuations inaccurate and volatile (e.g., sparsely population regions, unique property features, or low comparable sales). Adjustments Based on Valuation Method DBRS considers a full surveyor valuation as the U.K. standard, despite in certain situations it also being susceptible to a degree of inaccuracy. As a consequence, no adjustments are made to such valuations apart from indexation when appropriate (see below). The other property valuation methods, in some circumstances, are adjusted downward. This is done to take into account the potential risk of a property having been overvalued (which would imply a lower LTV than the actual; hence, PD and LGD measures would be underestimated). DBRS has undertaken an analysis of AVM performance for the three main U.K. AVM providers: Hometrack Data Systems Limited, UKValuation Limited and Rightmove plc. This analysis compares AVM-derived valuations with those provided by a full surveyor valuation or sales price. The relative over- or undervaluation compared with the surveyor valuation or sale price was calculated using the following equation, where positive differences represent relative overvaluation and negative differences represent relative undervaluation. Difference = AVM valuation – surveyor valuation AVM valuation For all three providers, the measures of confidence strictly determined the distribution of AVM valuation difference relative to the surveyor valuation. Increasing confidence measures were associated with decreasing variation from the accompanying survey or valuation (e.g., lower standard deviations). This general effect is shown in Figure 2.1a for three groups of confidence measures (i.e., confidence measures classified as high, medium or low). These distributions relate to individual properties and describe the potential differential amount an individual AVM-derived property value could have from a surveyor value. On a 29 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 portfolio basis, however, it is unlikely that all AVM-derived properties will have the same level of over- (or under-) valuation. Assuming a portfolio of 300 and randomly sampling from the property level distributions described above, the overall portfolio variation in accuracy is much reduced (see Figure 2.1b). Probability Figure 2.1a: AVM-Derived Valuations from Surveyor Provided Valuations for Individual Properties -100% -75% -50% -25% 0% 25% 50% Undervaluation 75% 100% Overvaluation Med. Confidence Measure Low Confidence Measure High Confidence Measure Probability Figure 2.1b: AVM-Derived Valuations from Surveyor Provided Valuations for Property Portfolios -6.0% -5.0% -4.0% -3.0% -2.0% -1.0% 0% 1.0% 2.0% 3.0% Undervaluation 4.0% 5.0% 6.0% Overvaluation Low Confidence Measure Med Confidence Measure High Confidence Measure DBRS haircuts AVM-derived valuations on the basis of the provider’s measures of confidence (and, therefore, associated potential variation from a surveyor value). Measures of confidence for each provider have been divided into three ranges; namely, low, medium and high. Each range is associated with a standard deviation of the AVM-derived value from the surveyor value as predicted by the confidence measure. For each range of confidence measures, the potential portfolio difference (at the 99% confidence level) has then been calculated. This estimate gives the associated haircut DBRS assigns to each range. For each AVM provider, Table 2.1 shows the range of confidence measures used to distinguish between low, medium and high confidence measures. It also provides the associated standard deviations and subsequent valuation haircuts. Table 2.1: AVM Provider Confidence Measure Ranges and DBRS Associated Valuation Haircuts Confidence Measure (CM) Range Hometrack 30 0 to 7 Low CM <= 3.5 Medium 3.5 < CM < 5.5 High CM >= 5.5 UKValuation 0 to 5 CM <= 2.2 2.2 < CM < 3.3 CM >= 3.3 Rightmove A to E CM = D or E CM = C CM = A or B Standard deviation of property difference from surveyor valuation >=20% <20%, >12% <=12% 99% confidence level of portfolio difference from surveyor valuation 4% penalty 2% penalty 1.25% penalty U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 DBRS does not adjust AVM-derived valuations on the basis of characteristics such as property size (e.g., very large or very small property valuations), location (e.g., more sparsely populated regions) or property type (e.g., bungalow or detached house). Although these features are associated with valuation accuracy difficulties (due to the small number of comparables, or reference properties), they are highly correlated with all the AVM providers’ measures of accuracy. This means that AVM-derived valuations for properties with these features tend to have lower confidence or higher uncertainty measures overall. Therefore, given that DBRS adjusts AVM- derived valuations on the basis of the associated accuracy measures, further penalties would double count the valuation risk for these property types. Note that DBRS applies a 2% and a 1.5% haircut to all desktop and drive-by derived property values respectively. Property Indexation The MVD is applied to the estimated property value at the time of the portfolio assessment. Property valuations are updated by indexing their given valuation according to a blend of the Halifax House Price Index12 and the Nationwide House Price Index.13 Average house price appreciation is applied to the property value up to six months prior the date of the portfolio assessment. House price inflation adjustments are calculated on a region-dependent basis. In addition to this, DBRS’s approach is to account for only 50% of the average reported increase. In the case of negative appreciation, however, the whole depreciation is applied. Table 2.2 shows an example of the property valuation update calculations for two properties located in different regions and with different dates of original valuation. Table 2.2: Valuation Update Calculation Examples Property and Valuation Details Property 1 Property 2 Location South East Wales Valuation date 15 January 2005 8 March 2004 Valuation GBP 210,000 GBP 126,000 Average house price at valuation date at location GBP 198,400 GBP 122,100 Portfolio assessment date 1 February 2007 1 February 2007 Average house price at portfolio assessment minus six months (1 August 2006) GBP 214,500 in August 2006 GBP 149,000 in August 2006 Average house price increase GBP 214,500 - GBP 198,400 = 8% GBP 198,400 GBP 149,000 - GBP 122,100 = 22% GBP 122,100 50% of house price increase 0.50% * 8% = 4% 0.50% * 22% = 11% Updated valuation GBP 218,400 GBP 139,900 Sale Price of the Foreclosed Property DBRS believes a forced sale as a result of property repossession will result in a discounted sale price relative to the norm. Therefore, although average historic house price indexes are useful in estimating potential MVDs for the housing market as a whole, they do not indicate how repossessed properties performed relative to the average. Adjustments to assumed MVDs for repossessed properties based on historical house price declines are usually made to capture additional risks associated with repossession sales, but there has been little published analyses on how these adjustments are derived. In addition, analyses of historical house price declines do not take into account how the sale prices of repossessed properties would behave in relatively benign economic environments, such as those experienced in the United Kingdom over the last four to five years. Given that DBRS uses this recent time period to benchmark future portfolio default rates, and therefore also to benchmark MVDs, it combines analyses from several data sources. Within this framework, foreclosed property MVDs have been estimated from portfolio historical loss performance, taking into consideration the cumulative default rates and LTV distributions. In addition, a significant added value 12. See www.hbosplc.com/economy/housingresearch. 13. See www.nationwide.co.uk/hpi. 31 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 to the analysis was also given by access to loan-level information for foreclosed properties, where both the original valuation, valuation date and repossession sale price were available. The ability to measure over time and for different regions how repossessed property values performed compared with normal sales was the main driver in the analytical approach DBRS adopted with regards to loss determination. The Benchmark MVD There is strong anecdotal evidence that foreclosed properties suffer from deferred maintenance (and often outright vandalism), which, combined with the pressure for a fast sale and the stigma associated with foreclosed properties, results in foreclosed property sale prices being significantly below those of the norm. Combined with this anecdotal evidence, DBRS had two main approaches in order estimate a benchmark MVD. – Approach 1: Over the last four to five years, property sales as a result of borrower default have been at historically low levels. Despite strong average house price increases over the same period, sale proceeds have not been enough to cover the outstanding loan principal in all cases. This is evidenced by securitised portfolios experiencing principal losses, particularly in the non-conforming section of the market. Figure 2.2 plots the average loss rate of over 80 securitisations backed by non-conforming U.K. mortgage portfolios, with the earliest date of securitisation in January 2000. Figure 2.2: Cumulative Average Loss for 80 Non-Conforming U.K. Transactions % of Principal Loss 0.75% 0.60% 0.45% 0.30% 0.15% 0.00% 0 12 24 36 48 60 Time Since Securitisation (Months) UK Non-Conforming Average + Standard Error of Mean – Standard Error of Mean The maximum LTV in the portfolios included in the above chart rarely exceeds 90%. Therefore, despite a large cushion of at least 10% to cover costs and strong house price growth on average, lenders are still experiencing principal losses. Therefore, the resale value of repossessed properties must be in some cases much less than the valuation at origination. DBRS has analysed a number of non-prime U.K. transactions and has back-solved to obtain average MVDs estimates by tracking cumulative defaulted property sales and cumulative losses, and assuming a certain weighted-average (WA) LTV and costs at default. Two portfolio examples of these calculations are given in Table 2.3. Note in Table 2.3 that LTV estimates have been obtained by analysing the LTV distribution at the time of securitisation and assuming that the higher LTV loans are more likely to default. Using this approach, the assumed LTV for defaulted loans was estimated to be around 88.5% on a weightedaverage basis across all analysed transactions (inclusive of 3.5% costs). The resultant MVD estimate from this analysis was calculated at approximately 23% to 24%. 32 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Table 2.3: MVD Estimation for Two Example Portfolios Variable Portfolio Example 1 Portfolio Example 2 Cumulative PD (actual) 4.4% 0.8% Cumulative loss (actual) 1.0% 0.1% LGD = Loss/PD (actual) 22.7% 12.5% LTV of defaulted loans (estimated) 82% + 3.5% costs 86.5% + 3.5% costs Sale price (estimated) 85.5% - (85.5% * 22.7%) = 66.1% 90.0% - (90.0% * 12.5%) = 78.8% Market value decline (estimated) 100% - 66.1% = 33.9% 100% - 78.8% = 21.2% – Approach 2: DBRS integrated the above preliminary assumptions with analysis based on loan-level data. Data was assessed on a significant number of mortgage loans that had foreclosed between 2001 and 2006. As part of its assessment, DBRS updated the original valuation price, as previously indicated, and then compared it with the actual sale price at repossession. Loan-level MVDs were then computed based on the difference between expected sale price and actual foreclosed value. The average MVD obtained from this analysis was approximately 25%. As a result of the preceding two approaches, and given the similar results, DBRS assumes the benchmark MVD for foreclosed properties to be approximately 25%. MVD Benchmark Adjustments per Property The benchmark MVD is then altered on a property-by-property basis depending on various borrower and property factors that DBRS assumes to influence a property resale value. The resultant MVD per loan represents the decline in the repossessed property value in a single B environment. The factors that result in MVD adjustments are property location, property size and property type. – Property Location Adjustments: Historical house price trends in the United Kingdom have shown considerable and persistent regional differences. A simple rule of thumb is that the closer the property location is to London, the higher the volatility in historical price. Figure 2.3 plots average regional house prices in the United Kingdom since the early 1970s. As shown in the graph, three time periods where house prices fell can clearly be recognised. Figure 2.3: U.K. Historical House Prices £350,000 £250,000 £200,000 1989–1993 £150,000 £100,000 1980–1982 £50,000 Q2 2007 Q2 2005 Q2 2003 Q2 2001 Q2 1999 Q2 1997 Q2 1995 Q2 1993 Q2 1991 Q2 1989 Q2 1987 Q2 1985 Q2 1983 Q2 1981 Q2 1979 Q2 1977 £0 Q2 1975 Average Regional Price 2004–2005 £300,000 Time Greater London North Northwest East Midlands East Anglia Southeast Scotland Yorkshire & Humberside Wales West Midlands Southwest Northern Ireland 33 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Based on an analysis of the historical house price volatility indicated in Figure 2.3, DBRS has grouped the United Kingdom into three main regions, as seen in Table 2.4. Table 2.4: DBRS Regional Groupings for MVD Adjustments Group Regions MVD Adjustment 1 London, South East, South West, East Anglia (includes Northern Ireland) 1.1 2 East Midlands, West Midlands 1.0 3 North, North West, Yorkshire & Humberside, Wales, Scotland 0.85 Figure 2.4 plots the average worst MVD experienced for each group described in Table 2.4 for the three time periods when property prices fell in the United Kingdom. Group 1 regions clearly show the largest relative decrease in price compared with the two remaining groups. DBRS accounts for the MVD differences across regions by applying a multiple that adjusts the benchmark MVD (see Table 2.4). Average Worst MVD During Time Period Specified Figure 2.4: Average Worst MVD per Regional Group 35% 30% 25% 20% 15% 10% 5% 0% Group 1 Group 2 Group 3 Region 1980 to 1982 1989 to 1993 2004 to 2005 – Property Size Adjustments: Very expensive and inexpensive properties have more volatile and less liquid resale markets because of the more limited number of potential buyers. In addition, the scarcity of good comparable valuation benchmarks increases the potential for the valuation of these properties to be overestimated. As such, DBRS increases the MVD for property valuations for very expensive and inexpensive properties. To estimate the relative expense of a particular valuation, DBRS computes the valuation ratio. This ratio compares the valuation of the property with the average in its region at the time of valuation. Valuation ratio = Property valuation Average property valuation in region A valuation ratio of less than 1 indicates the property is valued below the average. A valuation ratio greater than 1 indicates the property is valued greater than average. DBRS has examined valuation ratio distributions over a range of regions and time periods for the U.K. property market. The distributions show very similar characteristics in terms of valuation ratio ranges, and as such, DBRS uses an amalgam of these distributions to determine property valuations that are considered extreme. DBRS increases the MVD for properties with valuation ratios in the lower and upper 10% of the distribution shown in Figure 2.5 (representing valuation ratios of less than 0.5 and greater than 1.8). 34 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Probability Figure 2.5: Valuation Ratio Distribution - 0.50 1.00 1.50 2.00 2.50 3.00 Valuation Ratio Lower 10% Cut-Off Upper 10% Cut-Off The multiple applied to the MVD for each valuation ratio is given in Table 2.5. Table 2.5: MVD Multiple for Valuation Ratio Ranges Valuation Ratio Range MVD Multiple <=0.40 1.10 >0.40 - <= 0.45 1.05 >0.45 - <= 0.50 1.025 >0.50 - <= 1.80 1.00 >1.80 - <=2.00 1.05 >2.00 - <=2.45 1.10 >2.45 1.15 – Property-Type Adjustments: DBRS considers that Right-To-Buy properties are also associated with increased MVDs upon foreclosure. Therefore, it applies an adjustment of 1.1 to properties bought within this scheme. – Overall MVD Adjustment Calculations: On a loan-by-loan basis, all adjustments are multiplied together to obtain a single property-level MVD adjustment. For example, a property may be located in London (1.1 adjustment) and be five times the average London valuation (1.15 adjustment). The total MVD for this property is therefore 1.1 * 1.15 = 1.265. This is then multiplied by the benchmark MVD (e.g., 25% * 1.265 = 31.6%) to obtain the base case MVD for this property. Sale Price of the Foreclosed Property: Overall Calculations For every loan in the mortgage pool, DBRS determines an updated valuation, with indexation applied up to six months prior the pool cut-off date, and then computes the expected sale price at repossession by subtracting from this value the associated MVD. Table 2.6 shows how DBRS assumptions would affect two loans originated in diverse locations and with different property features. Costs The lender bears a number of costs associated with loan delinquency, repossession and subsequent property resale; hence, these payments need to be subtracted from the sale proceeds. Costs include legal fees (e.g., as the result of possession, eviction and property sale procedures), expenditures associated with any property maintenance the sale requires and the estate agency charge. Estate agency fees are usually calculated as a percentage of the sale price of the property and are therefore based on the assumed property value after the MVD has been accounted for. Agency fees in the United Kingdom typically vary from 1% to 2% (plus VAT of 17.5%). DBRS assumes that property maintenance costs are also 35 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 a function of property size and considers that lenders will be exposed to fee payments of approximately 3% of the sale price Legal and other miscellaneous fees are assumed to be fixed at GBP 2,500. Prior Ranking Loans For second-lien mortgages, any prior ranking balance will be taken into account and deducted from the property foreclosure sale price. This derives from the fact that, as mentioned earlier, lien positions differentiate levels of subordination in the rights of creditors to receive proceeds in case of foreclosure. Table 2.6: Sale Price at Foreclosure Calculation Examples Property and Valuation Details Property 1 Property 2 Location South East Wales Valuation GBP 210,000 GBP 126,000 Average house price at GBP 198,400 valuation date at location GBP 122,100 Valuation ratio 1.06 1.03 Right-to-Buy Yes No Benchmark MVD 25% * 1.1 * 1 * 1.1 = 30.25% 25% * 0.85 * 1 * 1 = 21.25% Updated valuation GBP 218,400 GBP 139,900 Sale price at foreclosure GBP 218,400 * (100% - 30.25%) = 152,334 GBP 139,900 * (100% - 21.25%) = 110,171 LGD PER RATING LEVEL Foreclosure MVDs per Rating Level DBRS assumes that MVDs for foreclosed properties are a function of the prevailing economic situation. DBRS has assumed that MVDs increase as rating levels increase, and that instances of portfolio-wide market value declines at the high extremes (e.g., 45% to 55%) occur very rarely and under stressful economic scenarios (e.g., AAA). The MVDs applied to all properties (assuming no individual property adjustments) at each rating level are given in Table 2.7 (see Benchmark MVD = 25%). Rating-specific MVDs have also been given for two examples where the benchmark MVD has been altered on the basis of various property characteristics (i.e., property size and property location). Loan-Level and Portfolio-Level LGD Calculations On a loan-level basis, LGDs are computed for all rating scenarios using the following process. Firstly, the property value at foreclosure is estimated by combining all valuation adjustments (e.g., indexation and valuation method). The sale price at foreclosure is then derived using the appropriate loan-level MVD at each rating scenario. Given that MVDs are rating dependent, the assumed costs will then vary accordingly, because they are a function of the foreclosed sale price. LGD is then calculated by subtracting the expected foreclosed sale price from the EAD and adding costs and any existing prior ranking balance, and then dividing the remainder by the EAD itself. Calculating portfolio-level expected losses by simply taking the weighted average of the loan-level LGD and multiplying it by the portfolio-level PD could result in biased estimates. Portfolio-level expected loss is accurately derived only when it is determined as a weighted average on a loan-by-loan basis. This approach prevents the impact of different levels of co-variance between loan-level PD and LGD estimates. This approach, however, only results in a portfolio PD and a portfolio expected principal loss (EL) estimate per rating level, with no portfolio LGD estimate. Separate estimates of portfolio-level PDs and LGDs are required, however, to correctly run the subsequent cash flow analysis (to take into account the impact of the length of the foreclosure process on lost interest). As such, portfolio LGD values are derived from the portfolio PDs and corresponding correctly calculated ELs (as described above) by dividing the portfolio EL by the portfolio PD at each rating level. 36 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Table 2.7: MVD Distributions for Benchmark MVDs Rating Level Benchmark MVD = 25% Benchmark MVD = 27.5% Benchmark MVD = 21.3% AAA 50.3% 52.8% 46.6% AA (high) 44.7% 47.2% 41.0% AA 43.5% 46.0% 39.8% AA (low) 42.5% 45.0% 38.8% A (high) 41.1% 43.6% 37.4% A 40.0% 42.5% 36.3% A (low) 39.0% 41.5% 35.3% BBB (high) 37.2% 39.7% 33.5% BBB 35.2% 37.7% 31.5% BBB (low) 32.7% 35.2% 29.0% BB (high) 31.5% 34.0% 27.8% BB 29.5% 32.0% 25.8% BB (low) 27.8% 30.3% 24.1% B (high) 26.0% 28.5% 22.3% B 25.0% 27.5% 21.3% B (low) 23.7% 26.2% 20.0% 37 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Part 3: U.K. Residential Mortgage Prepayment Criteria DBRS has developed a loan-level prepayment model to estimate base case prepayment behaviour for U.K. RMBS transactions. The core of this analysis was a detailed assessment of historical prepayment rates shown by U.K. RMBS mortgage pools. This analysis indicated a number of important determinants of prepayment behaviour, shown below: • Interest rate type (e.g., Fixed (Short Term), Discount (Short Term), SVR, etc.). • Time from origination to date of any interest rate reversion. • Time from loan analysis date to any interest rate reversion. • Credit quality of the underlying borrower. • Loan lien position. • Arrears status. • Occupancy (owner-occupied or BTL). In order to create a loan-specific prepayment vector through time, each loan is assigned to one of five standard prepayment vectors, depending on lien position and overall rate type (either tracker or SVR, or reverting loan with either one, two or three years to reversion from time of origination). These vectors are then adjusted further on the basis of the credit quality of the underlying borrower, whether the loan is for BTL purposes, or whether the loan is in arrears. This analysis produces a total of 20 possible vectors (see Figures 3.1, 3.2, 3.3, 3.4 and 3.5). Note that in all cases prepayments trend upwards in the first three to four years since origination and then plateau at the constant rate thereafter. This trend is primarily driven by the experience that in the first few years of a mortgage loan, borrowers are less likely to move to a new home, less likely to refinance, and their financial situation during this early stage does not usually allow for extra payments. The curves differ in the overall pattern of prepayment, and the influence of the timing of the rate reversion is clear. Borrowers are more likely to repay in the months following a rate reversion, as typically, reversions result in higher overall interest payments. Second-lien prepayment curves are even more front-loaded, given that many borrowers take these out while awaiting a rate reversion (and thus end of prepayment penalties) on their main mortgage loan. Once the main mortgage loan switches, the borrower then refinances the first and second-lien positions in a single re-mortgage. In addition, second-lien interest payments are typically higher than first-lien positions and therefore borrowers will attempt to repay these loans earlier. Due to the risk-based pricing strategies adopted by many lenders in a benign economic period, borrowers with past credit problems are also more likely to prepay than prime borrowers, as they will be able to “credit cure” in this environment and then refinance at a lower interest rate. Loans in arrears typically show the lowest prepayment rates historically, as once a borrower is in arrears, refinance options become more limited. 38 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 60 54 48 42 36 30 24 18 6 12 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.1: Prepayment Vectors - Loans on a 1-Yr Fixed/Discount Rate Before Reversion by Loan-Category Loan Seasoning Past Credit Problems/Self-Cert Prime Buy-To-Let In Arrears 60 54 48 42 36 30 24 18 12 6 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.2: Prepayment Vectors - Loans on a 2-Yr Fixed/Discount Rate Before Reversion by Loan-Category Loan Seasoning Past Credit Problems/Self-Cert Prime Buy-To-Let In Arrears 60 54 48 42 36 30 24 18 12 6 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.3: Prepayment Vectors - Loans on a 3-Yr Fixed/Discount Rate Before Reversion by Loan-Category Loan Seasoning Past Credit Problems/Self-Cert Prime Buy-To-Let In Arrears 39 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 60 54 48 42 36 30 24 18 6 12 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.4: Prepayment Vectors - Loans on Standard Variable Rate by Loan-Category Loan Seasoning Past Credit Problems/Self-Cert Prime Buy-To-Let In Arrears 60 54 48 42 36 30 24 18 6 12 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.5: Prepayment Vectors - Second-Lien Loans by Loan-Category Loan Seasoning Past Credit Problems/Self-Cert Prime Buy-To-Let In Arrears One vector is assigned to each loan on the basis of the loan’s underlying characteristics, and is adjusted for loan seasoning. As such, a seasoned loan will be assumed to be “further along the curve” and will show a different profile of prepayments going forward than a non-seasoned loan. The result of the vector assignment and seasoning adjustment creates a loan-specific prepayment vector for each loan in the portfolio. In order to create a portfolio view of future prepayment behaviour, an average prepayment curve (weighted by balance) is then calculated. An example using five loans is given in Table 3.1 and Figure 3.6. Table 3.1: Loan Description for Prepayment Example 40 Loan Loan Seasoning Base Prepayment Vector Interest Product 1 6 Prime 2 10 In Arrears 1 year to switch GBP 275,000 31.6% 3 24 Buy-to-Let 3 years to switch GBP 175,000 20.1% 4 2 Past credit problems/self-certication 1 year to switch GBP 145,000 16.7% 5 15 Past credit problems/self-certication Second lien GBP 25,000 2.9% SVR Balance GBP 250,000 Pool Percentage 28.7% U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 60 54 48 42 36 30 24 18 6 12 65% 60% 55% 50% 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 0 Annual CPR Figure 3.6: Prepayment Vectors - Example of Loan Level and Portfolio Level Estimates Time Since Securitisation Loan 1 Loan 2 Loan 3 Loan 4 Loan 5 Portfolio Note that DBRS considers the time period over which the prepayment model was created to represent very benign economic conditions in the United Kingdom, and was also one that promoted high prepayment levels (e.g., falling or steady interest rates, high levels of competition, benign economic environment allowing for credit curing, etc.). As such, DBRS considers the prepayment rates given in Figures 3.1 to 3.5 to represent near-maximum levels, as any deterioration in the economic environment is likely to lead to a contraction of prepayment rates. 41 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Part 4: U.K. Residential Mortgage Loan Aggregation Criteria Part of the DBRS loan-level analysis for U.K. mortgage portfolios includes standardised criteria for the creation of rep lines to aid the accuracy and efficiency of cash flow modelling. The loan characteristics that contribute to the creation of aggregated payment profiles are the following: • Interest rate type (e.g., SVR, Tracker(For Life), Fixed(For Life), Tracker (For Life with Teaser), Tracker (Short Term), Fixed (Short Term), Discount (Short Term)). • Payment profile (e.g., IO, repayment, or short-term IO). • Time for loan analysis date to any interest rate reversion. • Remaining Term (i.e. <=10, <=20, >20 years to maturity). • Time to Switch (0 to 12, 13 to 24, 25 to 36, and 36+ until switch date for Tracker (For Life with Teaser), Tracker (Short Term), Fixed (Short Term), Discount (Short Term) interest rate types). In combination, this creates 171 possible loan aggregations within the portfolio. For each rep line, the following fields are reported: • Total balance. • Weighted-average original term. • Weighted-average remaining term. • Weighted-average maturity date. • IO end date (for short-term IO payment profiles). • Weighted-average current coupon. • Weighted-average current margin (not available for Fixed (For Life), Fixed (Short Term)). • Weighted-average time to product switch (for Tracker (For Life with Teaser), Tracker (Short Term), Fixed (Short Term), Discount (Short Term)). • Weighted-average remaining term at switch (for Tracker (For Life with Teaser), Tracker (Short Term), Fixed (Short Term), Discount (Short Term)). • Weighted-average stabilised margin. An example of the rep line outputs from the DBRS U.K. Residential Mortgage Loan Analysis Model is given in Appendix D. 42 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Concluding Remarks The DBRS U.K. Residential Mortgage Loan Analysis Methodology sets the analytical framework for the DBRS U.K. Residential Mortgage Loan Analysis Model. This model is the quantitative tool that DBRS uses to assess the credit quality of U.K. mortgage loans, create base case prepayment assumptions, and produce standardised cash flow rep lines. The model is available free of charge and in an open format. These features stem from the DBRS aspiration to be fully transparent to the market in terms of its own modelling approach, but also to give users control over the assumptions, allowing them to conduct their own sensitivity analysis and stress testing, if desired. DBRS welcomes comments from market participants on the approach and assumptions outlined in this article. Please send your feedback to emalavasi@dbrs.com or vjohnstone@dbrs.com. 43 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Appendix A: The DBRS U.K. Residential Mortgage Loan Analysis Model To access the DBRS U.K. Residential Mortgage Loan Analysis Model, please visit www.dbrs.com/ukrmbs. Note: The model requires loan-level data, and as a consequence it will only be functional to market participants who have access to this information. This access increasingly includes investors, but in the current climate of uncertainty surrounding market abuse rules, the general dispersion of loan-level data records may be under some revision. At present, there is no consistent practice to ensure that all potential investors in a deal have access to the same loan-level data and also a lack of clarity as to whether this data constitutes insider information. DBRS considers the full disclosure of its methodology and the outputs of the loan analysis a crucial part of the rating process. The output of the model, which includes a detailed review of the portfolio, the main credit drivers and the rating scenario estimates (known as the tear sheet, see Appendix B), will therefore be made available on a timely basis as part of the DBRS rating and ongoing surveillance process. 44 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Appendix B: The DBRS U.K. Mortgage Loan Analysis Model Example Tear Sheet DBRS TEAR SHEET: Page 1 Table 1: Overview DBRS PD Drivers Basic Pool Description Number of Loans Current Balance Average Loan Size Largest Loan Largest Property Smallest Property 200 20,268,898 101,344 525,764 750,000 59,000 WA Original LTV WA Given LTV WA Valn Method LTV WA Indexed LTV WA Full Adjust LTV LTV Used to Analyse WAC WA Original Term (months) WA Remaining Term (months) WA Seasoning (months) 0.125% x Portfolio Portfolio Portfolio WA Credit Risk Band 1.98 x Default Rate LGD Expected Loss MVD 27.51% 24.43% 21.21% 19.64% 18.11% 17.25% 15.95% 14.45% 12.98% 11.60% 9.10% 7.97% 7.07% 6.07% 4.83% 39.49% 32.71% 31.30% 30.16% 28.56% 27.31% 26.18% 24.14% 21.88% 19.07% 17.74% 15.54% 13.67% 11.75% 10.71% 10.86% 7.99% 6.64% 5.92% 5.17% 4.71% 4.18% 3.49% 2.84% 2.21% 1.61% 1.24% 0.97% 0.71% 0.52% 49.3% 43.7% 42.5% 41.5% 40.1% 39.0% 38.0% 36.2% 34.2% 31.7% 30.5% 28.5% 26.8% 25.0% 24.0% Benchmark PD 76.2% 76.1% 76.1% 75.7% 75.7% FULLY ADJUSTED 6.33% 279.9 276.0 3.8 Rating Output CCJs 1.14 x Bankruptcy 1.13 x LTV 1.61 x BTL 1.08 x LTI 1.04 x RTB 1.04 x Fast Track 1.00 x Self Cert 1.34 x Self Employed 1.06 x Single Income 1.11 x Remortgage 1.00 x IO 1.11 x Term 1.07 x Jumbo 1.04 x 2nd Lien 1.00 x Interest Product 1.13 x Credit Risk Layer 1.04 x Extra 1.00 AAA AA (high) AA AA (low) A (high) A A (low) BBB (high) BBB BBB (low) BB (high) BB BB (low) B (high) B The portfolio default rate is the percentage of the portfolio assumed to default in each rating scenario. = Base Case 2 Yr 1.35% x 3.55 x 1 Seasoning Multiple Low PD Scaling The portfolio LGD is the percentage of defaulted loan amounts not recovered in each rating scenario. = Base Case LT 4.83% Assumed Correlation 13.9% Table 3: Lien Table 2: Past and Current Credit Performance Credit Risk Band Score No Score Sum A 0 0 0 B 0 136 136 C 0 37 37 D 0 13 13 E 0 14 14 Sum 0 200 200 Credit Risk Band Score No Score Sum A 0.0% 0.0% 0.0% B 0.0% 67.9% 67.9% C 0.0% 17.4% 17.4% D 0.0% 7.0% 7.0% E 0.0% 7.7% 7.7% Sum 0.0% 100.0% 100.0% Lien First Second Sum SVR Tracker(Short Term) % of portfolio Credit Risk Band Distribution 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Num. 200 0 200 Pct 100.0% 0.0% 100.0% Num. 1 0 0 8 182 0 9 0 200 Pct 1.0% 0.0% 0.0% 3.1% 92.1% 0.0% 3.8% 0.0% 100.0% Table 4: Mortgage Product Tracker(For Life w Teaser) Tracker(For Life) Fixed(Short Term) Fixed(For Life) Discount(Short Term) Other Sum See "Rep Lines" sheet for more granular data with respect to the Mortgage Product type (e.g., time to maturity, time to switch, WA coupon, WA margin etc) A CCJs Amount <=100 >100 - <=2000 >2000 - <=5000 >5000 Sum Expected loss in "B" environment (represented by UK mortgage performace 2001 to 2006 ) B Number 189 5 3 3 200 Pct 94.5% 1.6% 1.8% 2.1% 100.0% Bankrupt Number Yes 8 No 192 Sum 200 Pct 3.8% 96.2% 100.0% C D E Arrears Number 0 150 1 19 2 16 3 4 4 7 5 4 6 0 7 0 8 0 9 0 10 0 11 0 12+ 0 Sum 200 Pct 74.9% 8.0% 9.0% 1.4% 5.1% 1.5% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% Table 5: Right to Buy RTB Number Fail 9 Pass 191 Sum 200 Pct 2.6% 97.4% 100.0% Debt/Equity Remortgage Number Y 0 N 200 Sum 200 Pct 0.0% 100.0% 100.0% Table 6: Loan Type 45 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 DBRS TEAR SHEET: Page 2 Table 7: Loan-to-Value Number 26 12 30 51 53 27 1 0 200 Pct 8.8% 4.9% 13.8% 25.8% 29.9% 16.3% 0.4% 0.0% 100.0% Average 39.5% 55.5% 65.1% 75.4% 85.5% 92.2% 95.1% 0.0% LTV Distribution 60% 50% % of portfolio LTV <=50 50 to <=60 60 to <=70 70 to <=80 80 to <=90 90 to <=95 95 to <=100 >100 Sum 40% 30% 20% 10% 0% <=50 50 to <=60 60 to <=70 70 to <=80 80 to <=90 90 to <=95 95 to <=100 >100 Table 8: Region Information Region East Anglia East Midlands London North Northern Ireland North West Scotland South East SouthWest Wales West Midlands Yorks & Humber Unknown Sum Num 4 7 8 23 14 38 29 18 4 12 18 25 0 200 Pct 2.5% 4.0% 9.7% 8.4% 5.5% 18.6% 11.2% 10.6% 3.1% 5.3% 9.8% 11.3% 0.0% 100.0% Num Jumbo Pct Jumbo Ave Loan 0 0.0% 126,026 0 0.0% 116,608 1 2.6% 245,983 0 0.0% 74,000 0 0.0% 79,245 0 0.0% 99,231 0 0.0% 78,362 0 0.0% 119,320 0 0.0% 159,397 0 0.0% 88,977 0 0.0% 109,855 0 0.0% 91,820 0 0.0% 0 1 2.6% Ave Valn 162,490 158,613 304,946 110,600 169,772 133,772 99,531 171,867 225,820 121,472 169,833 119,392 0 Table 9: Income (Applies to Non-BTL Loans Only) Low Valn High Valn 0 0 0 1 0 1 3 1 4 1 6 0 4 0 2 0 0 0 2 0 1 1 2 0 0 0 24 5 Ave Benchmark MVD 27.50% 25.18% 28.02% 21.74% 28.24% 21.49% 21.51% 27.58% 27.50% 21.57% 25.24% 21.31% 0.00% Table 10: Credit Risk Layering Income Verf. Verified Fast Track Self Cert Number 93 0 92 Pct 48.0% 0.0% 45.9% Single Income Y N Sum Num. 61 32 93 Pct 30.3% 17.7% 48.0% Self Employed Verified Self Cert Sum Number 21 25 46 Pct 9.1% 10.9% 20.0% High LTI Fail Pass Sum Num. 4 89 93 Pct 1.9% 46.0% 48.0% Number 29 0 171 200 Pct 20.4% 0.0% 79.6% 100.0% Term >25 Years <= 25 Years Sum Num. 38 133 171 Pct 17.3% 62.4% 79.6% Number 183 14 2 1 0 0 0 0 0 0 0 200 Pct 90.5% 7.2% 1.3% 1.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% Credit Risk Layer 1 2 3 Sum Num 1 0 1 2 Pct 0.4% 0.0% 0.5% 0.9% 1 = LTV >= 95% & Self Cert/High LTI 2 = LTV >= 90% & Past CCJs/Bankrupt 3 = LTV >= 90% & Past CCJs/Bankrupt & Self Cert/High LTI Table 11: Loan Type Repayment IO Short Term IO Repayment Sum Seasoning <=6 Mths 6<=12 Mths 12<=18 Mths 18<=24 Mths 24<=30 Mths 30<=36 Mths 36<=42 Mths 42<=48 Mths 48<=54 Mths 54<=60 Mths >60 Mths Sum 46 % of portfolio Table 12: Seasoning Seasoning Distribution 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% <=6 Mths 12<=18 Mths 24<=30 Mths 36<=42 Mths 48<=54 Mths >60 Mths U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 DBRS TEAR SHEET: Page 3 Table 13: Buy to Let BTL Number Yes 15 No 185 Sum 200 Pct 6.1% 93.9% 100.0% WA ICR Through Time (Using Calculation Input Assmptions 140% 130% % of portfolio 120% Time Period WA ICR Current 116.7% 6 116.5% 12 118.5% 18 110.8% 24 95.1% 30 96.7% 36 98.2% 42 99.8% 48 101.3% 110% 100% 90% 80% Current 6 12 18 24 30 36 42 48 47 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Appendix C: Loan-level Example Computations of Lifetime PD, LGD and EL Example 1 Loan Information Computed Fields Original Loan Amount Current Loan Amount Prior Charge Amount Origination Date Maturity Date Repayment Type Loan Purpose Right-to-Buy Buy-to-Let Rental Income Current Rate Type 200,000 200,000 0 21 Sep 2006 Sep 2026 IO Purchase N N N/A SVR Property Information Region Last Valuation Last Valuation Date Valuation Method West Midlands 230,000 15 Aug 2006 Surveyor Borrower Information Income Verification Primary Income Secondary Income Self-Employed Verified 45,750 0 Y Performance Information Current Arrears Status (# months)) Total Amount of Past CCJs Date of Most Recent CCJ Prior Bankruptcy or IVA 0 0 n/a N Securitisation Date 01 Apr 2007 Seasoning (number of months) 6 AVG House Price Appreciation (credit to 50%) 0% Adjustment for Valuation Method 0% Current Property Value 230,000 Current LTV 87.0% Original LTV 87.0% Loan-to-Income 4.37 Credit Risk Band B Credit Risk Band Multiple CCJ Multiple Bankruptcy Multiple LTV Multiple BTL Multiple LTI Multiple RTB Multiple Fast Track Multiple Self Cert Multiple Self Employed Multiple Single Income Multiple Debt/Equity Re-mortgage Multiple IO Multiple Term Multiple Jumbo Multiple 2nd Lien Multiple Product Type Multiple Risk Layer Multiple Seasoning Multiple 1 1 1 1.94 1 1.25 1 1 1 1.15 1.25 1 1.35 1 1 1 1 1 2.67 Estimating PD Base Case 2-Year PD = 0.125% * 1.94 * 1.25 * 1.15 * 1.25 * 1.35 = 0.59% Base Case Lifetime PD = 0.59% * 2.67 = 1.58% Estimating LGD West Midlands: AVG House Price at Q3 2006 (i.e. valuation date) Valuation Ratio Market Value Decline* Estimated Sale Price At Foreclosure Costs 165,256 230,000/165,256 = 1.39 25% 230,000 * (100% - 25%) = 172,500 172,500 * 3% + 2,500 = 7,675 LGD = ( 200,000 – (172,500 – 7,675 - 0 ) ) / 200,000 = 17.59 Estimating EL EL = 1.58% * 17.59= 0.28% * No Adjustments to Benchmark MVD (i.e. due to Property Location, Property Size, RTB Scheme) 48 U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Example 2 Loan Information Computed Fields Original Loan Amount Current Loan Amount Prior Charge Amount Origination Date Maturity Date Repayment Type Loan Purpose Right-to-Buy Buy-to-Let Rental Income Current Rate Type 40,000 37,000 100,000 17 Jan 2006 Jan 2026 REP Purchase Y N N/A SVR Property Information Region Last Valuation Last Valuation Date Valuation Method West Midlands 150,000 5 Jan 2006 Surveyor Borrower Information Income Verification Primary Income Secondary Income Self-Employed Self Cert 50,000 15,000 Y Performance Information Current Arrears Status (# months)) Total Amount of Past CCJs Date of Most Recent CCJ Prior Bankruptcy or IVA 2 1,000 15 May 2005 N Securitisation Date 01 Apr 2007 Seasoning (number of months) 14 AVG House Price Appreciation (credit to 50%) 2.1% Adjustment for Valuation Method 0% Current Property Value 153,196 Current LTV 89.4% Original LTV 93.3% Loan-to-Income 2.1 Credit Risk Band D Credit Risk Band Multiple CCJ Multiple Bankruptcy Multiple LTV Multiple BTL Multiple LTI Multiple RTB Multiple Fast Track Multiple Self Cert Multiple Self Employed Multiple Single Income Multiple Debt/Equity Re-mortgage Multiple IO Multiple Term Multiple Jumbo Multiple 2nd Lien Multiple Product Type Multiple Risk Layer Multiple Seasoning Multiple 4 2.45 1 2.06 1 1 1.10 1 1.35 1.15 1 1 1 1 1 1.50 1 1 2.13 Estimating PD Base Case 2-Year PD = 0.125% * 4 * 2.45 * 2.06 * 1.10 * 1.35 * 1.15 * 1.50 = 6.46% Base Case Lifetime PD = 6.46% * 2.13 = 13.76% Estimating LGD West Midlands: AVG House Price at Q1 2006 (i.e. valuation date) Valuation Ratio Market Value Decline* Estimated Sale Price At Foreclosure Costs 158,501 150,000/158,501 = 0.95 25% * 1.10 = 27.5% 153,196 * (100% - 27.5%) = 111,067 111,067 *3% + 2,500 = 5,832 LGD = ( 37,000 – (111,067 – 5,832 - 100,000) ) / 37,000 = 85.85% Estimating EL EL = 13.76% * 85.85% = 11.81% * The adjustment to the Benchmark derives from the property having been bought within a RTB scheme. 49 50 >20 <=20 >20 <=20 <=20 >20 >20 >20 >20 <=20 <=20 >20 <=10 <=20 <=20 >20 <=20 <=20 39 112 108 109 6 113 54 55 51 71 75 35 5 74 44 50 40 REP REP REP IO REP REP IO IO REP REP REP IO REP IO IO IO REP REP Remain. Repay Term Type 43 Repline Number Fixed(Short Term) Tracker(For Life) Fixed(Short Term) Fixed(Short Term) Fixed(Short Term) Fixed(Short Term) Fixed(Short Term) Rate Type 0 - 12 24 - 36 24 - 36 12 - 24 12 - 24 12 - 24 Fixed(Short Term) Discount(Short Term) Fixed(Short Term) Tracker(For Life) Tracker(For Life) Fixed(Short Term) Tracker(For Life) 24 - 36 0 - 12 24 - 36 12 - 24 Discount(Short Term) 12 - 24 SVR Balance 44,458 52,780 56,944 63,141 91,753 110,250 173,923 201,443 219,329 244,695 245,306 253,492 302,191 512,227 852,455 2,071,903 4,236,786 12 - 24 10,535,822 Time to Switch Discount(Short Term) 12 - 24 Discount(Short Term) Sample Rep Lines 180 240 300 240 240 102 300 156 240 293 329 334 300 183 185 307 218 314 173 240 297 237 237 99 292 132 237 287 322 327 298 182 180 304 214 311 WA Orig. WA Remain. Term Term 08-Apr-2022 13-Oct-2027 12-Jul-2032 03-Aug-2027 20-Jul-2027 10-Jan-2016 25-Feb-2032 06-Nov-2018 22-Jul-2027 28-Sep-2031 25-Aug-2034 27-Jan-2035 18-Aug-2032 02-Dec-2022 23-Oct-2022 17-Feb-2033 17-Aug-2025 19-Sep-2033 WA Maturity Date 03-Aug-2027 25-Feb-2032 06-Nov-2018 27-Jan-2035 02-Dec-2022 23-Oct-2022 17-Feb-2033 IO End Date 6.35% 5.30% 5.70% 6.00% 5.95% 5.65% 7.01% 6.85% 6.70% 6.68% 5.77% 6.68% 6.69% 7.44% 7.01% 6.39% 6.15% 6.25% WAC -0.20% 0.50% 0.45% 0.69% 1.35% 1.20% 1.18% 0.27% 1.19% WA Margin 29 12 33 21 21 18 5 30 34 21 20 20 21 WA Time to Product Switch 144 228 264 78 216 269 317 298 147 158 283 194 290 12-Apr-2010 18-Oct-2008 19-Jul-2010 26-Jul-2009 28-Jul-2009 01-May-2009 27-Mar-2008 13-Apr-2010 30-Aug-2010 12-Aug-2009 12-Jul-2009 06-Jul-2009 15-Jul-2009 2.70% 1.90% 2.00% 2.25% 2.20% 2.02% 2.86% 3.40% 2.95% 2.48% 2.53% 3.27% 3.16% 3.49% 3.41% 2.83% 2.59% 2.85% WA Remain. Term at WA Date of Product WA Stablised Switch Switch Margin 0.22% 0.26% 0.28% 0.31% 0.45% 0.54% 0.86% 0.99% 1.08% 1.21% 1.21% 1.25% 1.49% 2.53% 4.21% 10.22% 20.90% 51.98% % of Pool U.K. Residential Mortgage Loan Analysis Criteria: Credit, Prepayment and Loan Aggregation November 2007 Appendix D: The DBRS U.K. Mortgage Loan Analysis Model Example Rep Lines Copyright © 2007, DBRS Limited, DBRS, Inc. and DBRS (Europe) Limited (collectively, DBRS). All rights reserved. The information upon which DBRS ratings and reports are based is obtained by DBRS from sources believed by DBRS to be accurate and reliable. DBRS does not perform any audit and does not independently verify the accuracy of the information provided to it. DBRS ratings, reports and any other information provided by DBRS are provided “as is” and without warranty of any kind. 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