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Basel ii in the United States of America
From the Basel ii Compliance Professionals Association (BCPA), the largest association of Basel ii Professionals in the world
 
Final Rule, USA: Risk-Based Capital Standards:
Advanced Capital Adequacy Framework — Basel II
 
Securitizations of Revolving Residential Mortgage Exposures
 
The agencies sought comment on the appropriateness of the proposed 4.5 percent excess spread trapping point and on whether there were other types and levels of early amortization triggers used in securitizations of revolving retail exposures that should be addressed by the agencies.
 
Although some commenters believed the 4.5 percent trapping point assumption was reasonable, others believed that it was inappropriate for securitizations of HELOCs.
 
Unlike credit card securitizations, U.S. HELOC securitizations typically do not generate material excess spread and typically are structured with credit enhancements and early amortization triggers based on other
factors, such as portfolio loss rates.
 
Under the proposed treatment, banks would be required to hold capital against the potential early amortization of most U.S. HELOC securitizations at their inception, rather than only if the credit quality of the underlying exposures deteriorated.
 
Although the New Accord does not provide an alternative methodology, the agencies concluded that the features of the U.S. HELOC securitization market warrant an alternative approach. Accordingly, the final rule allows a bank the option of applying either
 
(i) the CFs in Tables I and J, as appropriate, or
 
ii) a fixed CF equal to 10 percent to its securitizations for which all or substantially all of the underlying exposures are revolving residential mortgage exposures.
 
If a bank chooses the fixed CF of 10 percent, it must use that CF for all securitizations for which all or
substantially all of the underlying exposures are revolving residential mortgage exposures.
 
The agencies will monitor the implementation of this alternative approach to ensure that it is consistent with safety and soundness.
 

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