New York, March 28, 2012 -- Moody's announced today that student loan index change to one-month
LIBOR from three-month financial commercial paper (CP), pursuant
to the Supplemental Indentures, dated March 15, 2012 and effective
March 27, 2012, would not, , in and of itself,
result in the reduction or withdrawal of the outstanding ratings assigned
to student loan bonds (the "Bonds") issued by Mississippi Higher Education
Assistance Corporation Trusts ("Affected Transactions") at this time
After the index change, the Department of Education will calculate
special allowance payments (SAP) on the basis of a one-month LIBOR,
instead of the CP index used currently. This is credit positive
for LIBOR- indexed liabilities because it reduces basis risk in
that there are fewer sources of potential volatility between the two tenors
of one index (three-months versus one-month) than between
two different indices (LIBOR versus CP). For treasury-indexed
liabilities, the impact is neutral in that the change in the index
of the loans does not affect the average basis spread because the average
spread from 1971 to the end of 2011 between one-month LIBOR and
three-month CP has been similar. (See Index Change Is Credit
Positive for FFELP Student Loan ABS published 9 January 2012)
The change is being made pursuant to the Consolidated Appropriations Act,
2012, which allows holders of federally insured student loans under
the Federal Family Education Loan Program (FFELP) to permanently change
the interest rate index on the loans they own to one-month LIBOR
from CP, starting on 1 April 2012.
Senior bonds issued by Mississippi Higher Education Assistance Corporation
(1999 Indenture) will remain on review for possible downgrade following
a watch-listing action on 17 October 2011. That review was
prompted by the negative excess spread generated by the Bonds and the
amount of overcollateralization and cash in the trust accounts not providing
the notes with sufficient protection against the negative excess spread.
Furthermore, in the stress cash flow scenario the senior bonds may
stop receiving principal payment early in the cash flow which could further
decrease parity levels.
All Bonds issued by Mississippi Higher Education Assistance Corporation
(2004 Indenture) will remain on review for possible downgrade following
a rating action on 12 February 2012. The review was prompted by
discovery of an input error that had occurred during the previous downgrades
of the subordinate bonds on December 5, 2008 from A2 to Caa1.
Moody's ratings address only the credit risks associated with the transaction.
Other non-credit risks have not been addressed, but may have
significant effect on yield and/or other payments to investors.
This press release should not be taken to imply that there will be no
adverse consequence for investors since in some cases such consequences
will not impact the rating.
AFFECTED TRANSACTIONS:
Education Services Foundation 1996-01
Mississippi Higher Education Assistance Corporation (1999 Indenture)
Mississippi Higher Education Assistance Corporation (2004 Indenture)
RATING METHODOLOGY
In rating securitizations backed by student loans originated under the
Federal Family Educational Loan Program (FFELP), Moody's assesses
both the liquidity and credit risk of the transaction. The drivers
that affect the performance of a transaction include defaults, servicer
guarantee rejection rates, voluntary prepayments, basis risk,
borrower benefit utilization, and the number of borrowers in non-repayment
status, such as deferment and forbearance.
As part of our analysis to understand the risk of the underlying collateral,
we examine historical FFELP static pool performance data. To the
extent that performance data is available from a specific issuer,
that information is used to arrive at our cash flow assumptions for that
particular issuer. If an issuer's data are either limited or unavailable,
our assumptions are based on FFELP performance data received from other
participants. Although FFELP loans are a standardized asset,
we will assume additional volatility in certain assumptions for those
issuers that have limited or no data.
In addition, historical interest rates and spreads are analyzed
to evaluate the basis risk between the interest rate to which the bonds
are indexed and the interest rate to which the FFELP loans are indexed.
This historical data is used to derive an expected, or most likely,
outcome for each variable. These expected defaults, prepayments,
interest rates, and other assumptions are then stressed in accordance
with the rating categories requested by the issuer. Factors that
influence the stress levels include the availability of relevant issuer-specific
performance data, the seasoning of the loans, collateral concentrations
(school types, loan programs), the financial strength and
stability of the servicer, and the general economic environment.
These stressed assumptions are then incorporated into a cash flow model
that takes into account the FFELP loan characteristics as well as structural
(e.g., starting parity, cash flow waterfall,
bond tranching, etc.) and pricing features of the transaction.
The cash flow model outputs are analyzed to determine whether the transaction
as structured by the issuer has sufficient credit protection to pay off
the bonds by their legal final maturity dates. We also analyze
the liquidity risk of the transaction given that borrowers can be in non-repayment
status while in school, grace, deferment or forbearance status,
and the transaction can experience delays in default reimbursement and
other payments.
On November 18, 2009, Moody's updated its methodology to incorporate
an additional assessment of the risk posed by slow loan repayment rates
when analyzing bonds that are backed by FFELP student loans. We
have recently observed a considerable decline in actual repayment rates
of securitized FFELP student loan pools across issuers. The risk
posed by slow loan repayment rates is most pronounced for transactions
with negative excess spread, which have become more common in the
past two years. Under the updated methodology, the cash flows
of the transaction must be sufficient to make full and timely payments
to investors in a new repayment stress scenario in which the combination
of voluntary prepayments, defaults, forbearance rates,
and deferment rates results in a total repayment rate that is considerably
lower than our existing stress scenarios.
The rating agency condition for Affected Transactions was assigned in
line with Moody's existing methodology described above. Moody's
noted that on January 18th, 2011, it released a Request for
Comment, in which Moody's has requested market feedback on potential
changes to its rating methodology for FFELP securities.
Further information on Moody's analysis of these transactions is available
on www.moodys.com. Methodologies and factors that
may have been considered in the process of rating this deal can be found
in the Rating Methodologies sub-directory on Moody's website.
Please see ratings tab on the issuer/entity page on www.moodys.com
for the last rating action and the rating history.
Aleksandra Simanovsky
Associate Analyst
Structured Finance Group
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653
Barbara A. Lambotte
VP - Senior Credit Officer
Structured Finance Group
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653
Releasing Office:
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653
Moody's: No negative ratings impact on Mississippi student loan trusts from loan pool index change to one-month LIBOR