Mr. Richard Johns, Executive Director of SFIG
编者按 / Synopsis
相比之下，金融危机后的美国已对其证券化市场展开了深刻的反思和制度变革，其中的经验和教训无疑为我们提供了宝贵的借鉴。美国证券化行业组织（SFIG，Structured Finance Industry Group）的董事会秘书、资深法律专家Jason Kravitt，在2015年中国证券化论坛年会上主持的“美国证券化监管改革对中国的借鉴”的专题讨论，集结了来自美国证券化领域的各路精英，为我们全面剖析美国证券化市场发展的的问题和教训， 其中包括：（1）如何警惕证券化市场的膨胀信号，监督保证市场的适度发展；（2）从风险评估的实时调控来反思可交易性的弊端；（3）如何协调发行人、投资者、债务人等主体之间利益的一致性，以此保证资产的信用质量；（4）监管如何增加金融机构承担风险的能力并限制其参与高风险活动来控制系统性风险的发生；（5）重视信息披露的透明度以及加强监管规则应对复杂化的结构产品的更新等等；（6）精简出10条美国证券化危机中得来的教训；（7）最后对中国资产证券化市场目前的发展阶段作出了相应评价和建议。
As the first country to carry out the securitization in the world, the United States has formed a relatively complete securitization operation and management mechanisms in practice. And its market experience can safeguard the healthy development of the industry for China's asset securitization market, which is in development.
In "2015 Annual Conference of China Securitization Forum" , SFIG's Executive Director, Mr. Richard Johns, delivered a keynote speech. In which, he introduced the promotion of securitization to the real economy and offered a proposal for the development of China Securitization, with particular emphasis on "Simple, Transparent, Comparable" standard, and finally made a comment on how to build regulatory measures.
The following is the record of Mr. Richard Johns keynote share.
演讲实录/ Transcript of the speech
Thank you very much for inviting me here today. It is a great honor and opportunity to be your keynote speaker.
Before I jump in, I would like to clarify that while many of my comments today may very well mirror positions established by the Structured Finance Industry Group, commonly known as SFIG, via its membership, they are not specifically designed to do so and represent my own views and not those of our members. At this time, I would also like to recognize Moody’s Investor Service, who provided much of the data that I will use to here today.
A. Brief Introduction to SFIG
Let me begin by explaining a little about our organization. SFIG has approximately 300 institutional members representing all segments of the securitization industry, including issuers, investors, broker dealers, servicers, trustees, rating agencies, law firms, and accountants. In short, SFIG’s membership is a broad cross-section that is truly representative of the entire securitization industry. As an organization we are centered on one core premise – notably that Securitization is an Essential Source of Core Funding for the Real Economy. Our focus is on educating market participants and building consensus around policy issues and using that industry consensus to work with rule makers to support the responsible continued development of the securitization markets with a view to supporting that provision of funding to the real economy.
This conference highlights “Global Vision” in conjunction with “Stable Development,” I would like to begin by referencing the application of securitization within the U.S. and how that may ultimately extend to the Chinese economy. I will also review some of the key elements necessary to establish a liquid market, along with some of the safeguards that may need to be applied to ensure market growth is undertaken on a responsible and stable basis.
As an industry group, SFIG was formed by members who had grown dissatisfied with existing industry representation and elected to rebuild their voice, keeping all that was good about past organizations and looking to add improvements to make up for weaknesses experienced in the past. The similarity between those goals and the opportunity to share insight with the CSF by applying lessons from the past was not lost on our membership, nor were the goals of both the CSF organization and the Chinese regulators in terms of supporting funding of the real economy. SFIG immediately created a Chinese Market Committee, and I am pleased to say that the number of active participants makes that committee perhaps our most vocal out of all of SFIG’s committees.
B. How Securitization Supports the Real Economy
So let’s now turn to funding the real economy.
As the most developed capital market in the world, right now, the U.S. represents the largest use of securitization as a means to fund the real economy. Of the approximate $6 trillion of bond issuance in the U.S. during 2014, $1.6 trillion was related to securitization.
At 30 percent, ABS as a share of total bond issuance is significantly down from nearly a 50 percent share prior to the global credit crisis, but nevertheless still represents a significant part of the economy.
具体而言，这个市场包括抵押支持证券化（主要是通过政府赞助的实体Fannie Mae和Freddie Mac），以及汽车贷款，信用卡和学生贷款证券化。
To be specific, the markets we are talking about include: mortgage-backed securitization (primarily through the government-sponsored entities Fannie Mae and Freddie Mac), auto, credit card and student loan securitizations.
These securitization markets are fundamental aspects of everyday life. To put this statement in perspective, these markets allow consumers to live in a house at a reasonable interest rate, own a car to drive from that home to work, and stop at the grocery store on the way back home to buy food for their families. And as their children grow up, these same markets help fund their children’s student loans so that he or she can get a good job, buy their own car, afford their own house and hopefully allow their parents to enjoy retirement, knowing that their kids have been well educated, with good jobs, and a nice house.
However, securitization’s economic impact affects much more than just consumers. It also finances the commercial side of the economy.
Over $200 billion of loans to commercial enterprises were financed through securitization during 2014. Collateralized loan obligations, or CLOs, funded nearly half of the $843 billion of all leveraged loans outstanding at the end of 2014. That’s down from pre-crisis highs, but at close to half, it is still a very large number.
For automobiles, securitization produces much more than consumer car finance. It also finances the company that manufactures that car, such as GM and Chrysler – both of whom have used the CLO market. If you boarded a United, Delta, or American airlines plane to attend this conference, for example; you may very well have used an airline that has accessed the CLO market to receive financing. If you purchase a burger for lunch from Burger King, part of that burger’s cost helps pay the CLO that financed the very making of that burger.
Securitization also provides different products that companies may use to grow and create jobs. Beyond CLO’s, commercial mortgage-backed securities (“CMBS”) have funded $625 billion or 27 percent of the commercial mortgage market. In 2014, CMBS funded over 7,800 properties. This means that securitization also pays for the building you work in, the apartment where you live and the hotel where you vacation with your family.
Next let’s think forward to our retirement years. We’ve been paying the cash-flows into the securitization system all our lives through auto loans, mortgages and credit cards.
All of those payments have been providing a coupon to investors in asset-backed securities, or ABS, including the pension funds that hold our retirement savings that we have invested in during our working years. Those same investments will now help to pay for our retirement years.
Even in the later years of retirement, securitization continues to stimulate our ability to keep living through hospitals and assisted living facilities.
That is the way how securitization promote the development of the real economy.
C. How to prompt Securitization in Chinese Market?
However, we are not in the U.S., we are in China.Versus $1.6 trillion issued in the U.S., China is clearly a smaller market in comparison with just 3000 RMB, which represents 2 percent of the size of the U.S. market. But that 2 percent is expected to double again in 2015, and grow well into the future.
To start simply, there is the potential for further streamlining of the issuance process and the continued encouragement of banks to shift toward growth of smaller, consumer orientated companies. With continued growth in the auto sectors, Chinese auto production continues to lead the world and grow at 8 percent peryear. With the amount of CLO potential,the China Banking Regulatory Commission (“CBRC”) recently predicted that $14.4trillion dollars of outstanding bank loans may be eligible for securitization.
Just taking that expansion potential on its own, then layering in the re-introduction of RMBS in 2014 and the potential introduction of other asset classes such as consumer loans and equipment leases – there is a clear path for large multiple expansion in China over the forthcoming years.
The fundamental question then becomes “how does China make this expansion happen?” Or perhaps the more important question is “how does China make this happen without growing too fast?” The first is a question thatis almost entirely driven by markets and the second is about how markets should work effectively with regulation, which is a more challenging question.
Let’s discuss markets first. What does it take to make a market liquid? At a conceptual level, this may not be as hard a question as it first appears. Markets depend on supply and demand. To create an efficient and liquid market, both sides of that equation must be satisfied.
Let’s take the supply side first.
Issuers are not solely focused on attaining low cost of funds. While that is important, issuers also need to be confident that they can access the market through good and bad times. This certainty of execution element includes a few key points:
Low barriers to entry and the ability to repeat issue – If issuers aregoing to embed a form of financing into their strategic funding plan, then they have to be sure they can access that form of funding time and time again.
Price visibility – Issuers needa continued understanding of where a security is likely to price so that they have certainty as to whether it will be economical to bring a transaction to market. A liquid market therefore must give issuers an ability to benchmark issuance against a market and to understand what is driving the price.
Market resiliency – Issuers need to know that when they bring supply there will be demand; and therefore they need a deep and developed investor base.
Duration – Issuers also need to know that a transaction will not require immediate refinancing and may require the ability to transfer risk.
Transaction efficiency – Issuers must also be able to conduct transactions of sufficient size so that upfront structuring costs and fees can be amortized over the life of a deal and do not upend the efficiencies of the transaction.
On the demand side, investors are not solely focused on price. In fact, an investors’ needs in many ways mirror issuers’ needs.
Investors are not looking to make an investment in onesecurity. If they are going to put a lot of resources and effort into understandingan asset class or an issuer, while also spending time to educate staff - they want to know the investment opportunity will be repeated. They too need to know that they are getting a security at market price – so again they need pricevisibility, and an understanding of the factors that drive price and an abilityto monitor them. They need to be able to understand the asset class and the factors that drive performance; and they need full disclosure of what they deem to be material information, to have a full understanding of the risk they are being asked to buy.
In addition to the collateral itself, investors must have a clear understanding of the security’s structure so its performance will be transparent from the nature of the collateral. The more complicated a transaction, the less easily this connection can be made. Investors also need low barriers of entry into the market. And of course, in the event an investor wants to sell a security, they want to have a clear bid in the market to consider.
Right now, both the European Banking Authority and a joint IOSCO/Basel task-force are working to define a “standard” for transactions that might designate them as “high quality.”
While we at SFIG would urge some caution about therisk of creating a dividing line between what designates “good” and “bad” ABS on the basis that it could create a negative impact to anything that fails to meet the standard. However, the concepts adopted by IOSCO/Basel of “Simple;Transparent; Comparable” certainly warrant some additional discussion as they can be applied to helping to grow new markets.
We certainly would not want to encourage some of the structure of the past, such as collateralized debt-obligations (“CDOs”) squared, which introduced layers of leverage into a transaction. So perhaps “simple” is a good place to begin.
However, some of the best performing asset classes during the crisis, such as credit cards, actually do not have a simple structure. One could perhaps define thestructure as “straightforward,” on the basis that there was only one asset class and one set of cash flows, for example. A security’s performance is predictable based on an understanding of the nature of the asset in hand and the application of its cash-flows through a straightforward transaction structure. So a straightforward transaction may go along way towards meeting an investor’s needs.
Coming back to the IOSCO/Basel concepts, “transparency” is also important. A straightforward transaction in and of itself will help support transparency of a security’s performance. Additionally, there is a need to clearly define roles, responsibilities, review processes and enforcement actions, so that if something does go wrong, everyone knows who is supposed to be doing what; and the transaction begins to satisfy both issuer and investor needs.
Layer in appropriate regulations around disclosure of asset “point in time” and “performance” data, and investors will be provided with the ability to understand both the driving factors behind the security’s performance and also the hard data with which they can assess the risk they are taking.
However, investors will be unable to price that risk effectively without the ability to compare it to other similar risks, which is why the “comparable” criteria is also important. However,comparable does not mean all transactions need to be identical. In fact, it means the opposite. If transactions were identical, then they would never need to be compared. Different issuers will have different disclosure processes and may place different emphasis on different elements of information. Therefore, full standardization is not a positive outcome for a market. Yet, presenting recommended ranges of disclosure or best practice guidance is a very powerful way of ensuring that transactions are comparable, provided transparent disclosure of where one issuer differs from another is given. This is even more relevant for any growing market, where overly prescriptive standards will stifle innovation and potentially impact growth of that market.
That is a high-level overview of simple, transparent and comparable – with a slight tweak changing simple to straight forward.
But generally transactions should be clearly structured so that the performance can be derived from the performance of the asset. Information should be clearly disclosed to ensure that an investor can derive that information, and deals should be structured somewhat similarly so investors are able to view that information in an appropriate context and make sound investment decisions.
Let’s now turn to streamlining the issuance process. One thing that highly liquid markets depend on what I would loosely term “market velocity.” I don’t want to dwell too much on this aspect, but merely recognize that if we go back a year or so, whenissuers had to get each transaction pre-approved, the ability to be opportunistic in the market is lost. Issuers then become price takers, which is not an incentive to come to market.
Markets work off a somewhat paradoxical basis where scarcity of product does not necessarily drive price upwards. Prices increasewhen markets are deep and liquid; and a deep and liquid market requires more issuance (supply). In order to create more supply, issuers need flexibility to bring transactions to market. That means issuers need the ability to develop a transaction quickly when demand ishigh and to be therefore be able to access pre-constructed documents.
This brings more issuance, creating deeper liquidity,and the recent steps taken to eliminate the pre-approval process and allow issuers to register on a “shelf-like” basis is a large step forward, which we congratulate and applaud the regulators for taking.
Now on to price transparency.
The secondary market is absolutely key to ensuringU.S. markets work effectively. When an investor buys a bond on the market, he wants to ensure retains the ability to sell that bond. Having a market maker actively support the ABS market ensuring that when an investor wants to sell, there is a bid, and to be able to hold that bond until it can be offered ensures that investors feel confident to buy in the primary market and sends an additional signal to other investors that the bond is liquid.
Knowing what a bond trades like on the secondary market also provides insight into where a primary issuance should price, as an investor simply has to look to a similar risk/maturity profile in the secondary market and where it trades.
This price transparency works both in the favor of the investor and the issuer as everyone knows they will be buying new issue in theright “ball-park”. And of course those secondary market spreads also highlight to an issuer, where investors have the most appetite to invest.
In the U.S., the ABS underwriter is typically themarket maker in the secondary market and operates active secondary flow that offers ABS to other broker-dealers or third-party investors.
The secondary market is far more active in the U.S.versus Europe, where investors have tended to be far more buy-and-hold type investors, which has had a correspondingly negative impact on market liquidity,even in the years before the global credit crisis.
While we are talking about buying and selling assets on a market, it can sometimes be paradoxical to remember that there is no exchange in this process. In fact, this is particularly important in young markets with high growth potential but little history. Spreads need to be controlled efficiently without risk of market freefall or massive appreciation.Controlling volatility is a key element of a broker-dealers’ role. They will work within the confines of WallStreet with lists of bonds soliciting bids from other firms and similarly they may bid on lists offered by other firms’ lists.
It is an art form as well as a science, and without adoubt it is one of the key distinguishing factors that has been responsible forthe deep liquidity in the U.S. markets of today and the past, including the faster post-crisis recovery that was seen in the U.S. relative to other market jurisdictions.
I strongly believe that for the Chinese ABS markets to enjoy the level of liquidity and free trading of securities needed to support both ongoing liquidity and effective price discovery for primary market issuance. Just as importantly, an active secondary market, with off-shore banks as major contributors, is a key element to the future success of the Chinese ABS market.
So how can China grow the securitization markets to support responsible funding for the real economy?
Let’s come back to my list of supply and demand variables:
- 低门槛的进入市场并且有能力重复发行——投资者需要能够低门槛的进入市场以及能够重复发行。在发行人层面我们已经谈到了“ 阶梯式”的登记程序以及事前审批。考虑到时间有限，我不再赘述。
Low barriers to entry and the ability to repeat issue – Investors need low barriers to entry and the ability to repeat issue. We covered the issuer side with the shelf-like registrationand removal of pre-approval. I am going to keep moving on, but let’s not forget there is an investor entry barrier discussion to be had, which I will avoid now for the sake of time.
Price visibility – As I said before, investors also need price visibility, the continued understanding of where a security is likely to price so that an issuer is not guessing as to whether it will be economical to bring a transaction to market. An ability to benchmark issuance against a market and to understand what is driving the price from the secondary market totransaction comparability is also necessary
Market resiliency – Issuers need to know that when they bring supply there will be demand; and therefore they need a deep and developed investor base. Again, there is a conversation to be had about removing barriers to entry and educating off-shore investors.
Transaction efficiency –Issuers must also be able to conduct transactions of sufficient size so that upfront structuring costs and fees can be amortized over the life of a deal and do not upend the efficiencies of the transaction. While I have not discussed it, removal of deal quotas can make a big impact to transaction efficiency together with theability to use a shelf and repeat issue with effectively that same documents.
This bears repeating as it is a fundamental concept for building a liquid market. Investors are not just looking to make the investment in one security. They will put theeffort into getting to know an asset class or an issuer, spend time educating staff on said class or issuer and, because of all that effort they want to know the investment opportunity will be repeated.
They need to know that they are getting a security at market price – so again they need price visibility and an understanding of the factors that drive price and an ability to monitor them,such as transaction comparability and secondary market trading.
Investors must be able to understand the asset class and the factors that drive performance. They need full disclosure of what they deem material information that will provide a full understanding of the risk they are being asked to buy. This requirement makes both transparency and disclosure key.
Similarly, in addition to the collateral itself, investors need a clear understanding of the security’s structure so its performance will be transparent from the nature of the collateral. The more complicated a transaction, the less easily this connection can be made. Simplicity enhances the comparability of securities.
And of course, in the event they want to sell a security, investors want a clear bid in the market to take the sell the security through secondary markets.
Summarizing the key elements again, they are:
Straightforward, transparent and comparable deal structures;
A shelf process to encourage repeatable transactions;
Strong, developed secondary markets.
These three key elements are required to enable the growth of the Chinese markets. I would certainly add investor development and education, removal of off-shore barriers and other aspects as further areas of opportunity.
D. How to support the real economy?
Having covered how to build liquid markets, we should now address how to grow the markets to support the real economy responsibly.
This is where the industry working together effectively with regulators is of absolute and paramount importance, and the Chinese Securitization Forum is perfectly placed to provide an effective forum for such collaboration.
China really does have an opportunity to build something better than it has been built before. In thinking about this building process it is helpful to think about the fable of the three little pigs.
In the U.S. there is a fable about how “Mother Pig” sends her three sons off into the world to make their way in life. Pig number one is lazy and builds his house of straw, pig number two is a little less lazy but still not fully up to the task and builds his house of sticks and of course we have responsible pig number three who builds his house from bricks. Needless to say, the big bad wolf in this fable ends up blowing down the houses of pig one and two and they all have to seek refuge in pig number three’s house.
Build your house of bricks. There will inevitably bean other crisis. Market bubbles happen. Market upsets happen. Liquidity crises happen. What we have to do is ensure that when they do happen, we are prepared with market structures that can weather the storm and stay standing.
That means the industry must work in conjunction with regulators to determine market practices that work with regulation, and the China Securitization Forum is perfectly placed to provide a forum for suchcollaboration.
In general, regulation cannot be overly prescriptive,which can create a lack of flexibility in times when it is needed and is perhaps a bigger restrictor for growing markets which tend to be more evolutionary and therefore require more flexibility. This puts responsible behavior and adoption of best practices even more to the forefront for market participants.
It is important too that regulations do not conflict with one another. That does not mean every rule has to open the doors to securitization without any controls or protocols. Having a set of appropriate disclosure or risk retention rules may very well be in the interests of the securitization market as a whole in that it may align interests and ensure investors have enough information to make credit decisions.
As with any rule, broad and poorly defined requirements often have unintended or negative consequences. Take for instance Basel’s liquidity coverage ratio (“LCR”), which specifically eliminates banks from being able to classify any ABS holdings as liquid assets. This is particularly troubling from the perspective that many plain vanilla ABS categories, including prime auto and credit cards, out performed corporate bonds significantly. Eliminating banks as a potential investor in this product appears contrary to European, U.S. and Chinese goals of supporting private securitization capital as a means to providing meaningful finance to the real economy.
So let’s discuss a few regulations that may be worth considering.
ⅠAlignment of interests.
Alignment of interests is a good thing. It is no surprise that prime auto and credit card ABS performed well during the crisis. Auto manufacturers had an alignment of interests in that they had to have financing available to sell their cars and card issuers profit was driven by exactly the same performance factors that provided returns to investors.
However, if securitization becomes an actual business model as opposed to a form of funding, then the gain on sale can create a risk to such an alignment of interests.
Risk retention can also be a good tool for aligning interests. But, as I said before, broad rules have unintended consequences. It would be detrimental to develop one solution and apply it to each asset type without regard for the characteristics of that asset. Taking a model designed around mortgage and applying it against auto ABS for example, simply would notwork.
Going a step further, let’s look at CLO’s. Due to the different business models around CLOs in the U.S., where rather than being high quality loans originated by a bank that is both originator and issuer, the loans are sourced as leveraged loans through the secondary market and pooled via a collateral manager prior to issuance. Assessing a retention factor against a collateral manager who is not part of the origination structure createsa risk to the entire business model for the U.S. CLO industry. Interestingly,it may be more fitting to the Chinese CLO model.
However, the most important first step would be tomake sure that no “one-size-fits-all” approach is taken and that each regulation is crafted with the industry and always tested to ensure it meets the strategic goals of the regulation without hurting the very market it is designed to protect.
Ⅱ Transparency of information
Lack of transparency and diligence may have led to in appropriate risk assessment. The goal should be to increase transparency and incentivize investor diligence. This is not an easy balance to get right and is a subject that created enormous debate in both the U.S. and Europe.
The challenge is getting the balance right between:
Providing an investor sufficient information to allow for a well-informed credit decision;
Not creating an over-burden some regime that forces an issuer to disclose proprietary information or to incur too much cost in providing that disclosure – both of which can cause them to withdraw supply from the market.
Therefore, I have a few pieces of advice.
First, rules are necessary - not just to enforce transparency but also to promote consistency of disclosure.
Second, it is important to take an asset-by-asset approach. Different business models and loan products place different weight on various performance or credit criteria. For example, what is useful for are volving credit card pool is not going to be the same as what is necessary for an amortizing pool of auto receivables.
Let’s take a look at increased complexity in ABS structures.
There can be no doubt that the swift development of increasingly complex structures in the U.S. contributed to the financial crisis– in short, making it difficult for both credit rating agencies and sometimes regulators to remain up to date on new structures. Some of that may be cured by the need to keep deals “straightforward.”
There are other alternatives that may in some part gotoward mitigating this risk, which may include changes to rating agency models for example. However, beyond guarding against increased complexity in general, it would be wise to take a cautious approach to setting up rules targeted against complexities. Remember, simple and straightforward are not always the same.
There can be noreal substitute to appropriate levels of regulatory oversight. In short, a smarter regulator is a better regulator – and it must fall upon the industry to ensure it partners effectively with the regulators to share education around both product and market developments.
Ⅲ Not to take a broad brush
Systemic risk application when specifically applied to securitization has been overly punitive when we look within the U.S.
When you think about a model for off balance sheet transactions, where risk has been transferred, it is important to create acapital benefit for reductions in unexpected losses. Where accounting warrantsit, off balance sheet treatment should be allowed to reduce loss reserves.
To put these comments into context, in the U.S. thereis a misalignment between regulatory capital requirements and contractual agreements. From an accounting perspective, the U.S. accounting assumes that an issuer will choose to vary its contractual terms to absorb risk that had been transferred to the investor –and issuers are forced to hold capital against that risk of loss. When these assumptions are applied against the fact that an investor is also required to hold capital against the risk of the security, then regulatory structure creates two times the amount of capital in the financial system versus the expected risk. This outcome not only increases the cost of credit but also limits the supply of credit, two results that appear incongruent with the goals of providing funding to the real economy.
Ⅳ Encourage global consistency
This does not mean follow everyone else. It means engage globally to ensure that market participants understand the perspectives of all markets and have an opportunity to help shape an educated global regulator to adopt sensible rules that can be appropriately applied to protect all markets without harming liquidity.
In a short amount of time I have tried to lay out a“real economy” nirvana, coupled with how the industry can focus on developing sufficient long term and sustainable deep market liquidity while working with regulators and employ the best practices to ensure market participants are appropriately protected and, equally important, that markets are resilient to future crises.
Thank you for your time, again, we are deeply honored to have been invited here. And at this point I think maybe we can open it up for a few questions.
[This News is edited by the following professionals: (1) Jiang Qinjuan, Securitization Team of Zhong Lun Law Firm; (2)Wang Wenjuan, Securitization Team of Zhong Lun Law Firm; (3)Natalie Imamura, Secretariat of China Securitization Forum.]
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