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Announcement:

Moody's places on review for possible downgrade ten TFOVIS RMBS issued by FOVISSSTE in Mexico

22 Nov 2011

Mexico, November 22, 2011 -- Moody's de Mexico (Moody's) has placed on review for possible downgrade the Aaa.mx (sf) / Baa1 (sf) ratings of ten TFOVIS RMBS certificates issued by Fondo de Vivienda del Instituto de Seguridad y Servicios Sociales de los Trabajadores del Estado (FOVISSSTE) in Mexico. The collateral backing the affected transactions consists of first-lien, fixed-rate mortgages denominated in multiples of minimum wages (Veces Salarios Mínimos) and granted to primarily low-income borrowers employed in the public sector. FOVISSSTE services these mortgages via automatic payroll deductions.

The complete rating action is as follows:

Originator and Servicer: FOVISSSTE

Master Servicer: Administradora de Activos Financieros S.A. (ACFIN)

Issuer: HSBC México, S.A., Institución de Banca Múltiple, Grupo Financiero HSBC, División Fiduciaria (HSBC), acting solely in its role as trustee.

-- Place on review for possible downgrade the Aaa.mx (sf) (Mexican National Scale) and Baa1 (sf) (Global Scale, Local Currency) ratings of the Class A certificates from the following ten transactions: TFOVIS 09U, TFOVIS 09-2U, TFOVIS 09-3U, TFOVIS 10U, TFOVIS 10-2U, TFOVIS 10-3U, TFOVIS 10-4U, TFOVIS 11-U, TFOVIS 11-2U and TFOVI E11U.

RATINGS RATIONALE

Today's rating action reflects reporting inconsistencies that raise concerns about the quality, consistency, and clarity of the information in the TFOVIS securitizations' collections reports. Further, given that the collections reports do not necessarily reflect what FOVISSSTE states it is actually doing, assessing the combined impact of the reporting issues presents some difficulties.

The reporting inconsistencies do not apply to TFOVI E11U because the first payment date of this recently issued transaction has not yet taken place. Moody's nevertheless placed it on review because it is serviced on the same platform by the same parties as the other TFOVIS on review and is therefore subject to the same operational issues.

During the review period, Moody's will examine the procedures transaction parties follow to resolve the reporting inconsistencies, validate the quality of the collections reports and reconcile the historical cash flows to the trusts. Moody's will also assess the impact of all of the reporting issues and whether FOVISSSTE has deposited more or less money than it should have into the trust accounts.

In the meantime, Moody's maintains its Aaa.mx (sf) / Baa1 (sf) ratings on the affected certificates, albeit on review, due to the transactions' solid performance and structural protections. Because of FOVISSSTE's strong alignment of interests with investors, Moody's believes FOVISSSTE will promptly remedy any reporting issues that might expose the trusts to increased risk. If the parties involved achieve a satisfactory resolution to these issues, Moody's would remove the certificates from review status and confirm the current ratings.

OVERVIEW OF REPORTING INCONSISTENCIES

For further details, please refer to Moody's special comment titled "Moody's to review impact of reporting inconsistencies in FOVISSSTE Mexican RMBS", November 22, 2011.

Using information that FOVISSSTE provides as primary servicer, the master servicer (ACFIN) prepares the transactions' collections reports on FOVISSSTE's behalf as its delegated party. Both FOVISSSTE and ACFIN must validate the data in the collections reports, in which ACFIN reconciles FOVISSSTE's monthly mortgage collections and instructs FOVISSSTE how much to deposit into the securitization trust accounts.

The first reporting inconsistency is that in some periods, FOVISSSTE deposited into the trust accounts amounts that were significantly greater than the amounts that ACFIN instructed in the collections reports, while in other periods, it deposited amounts that were considerably lower. Per FOVISSSTE, it is now making deposits in accordance with the collections report instructions. According to FOVISSSTE, prior to the September 2011 reports, rather than depositing collections per ACFIN's instructions, it had been making deposits based on its own internal calculation, which included its own estimate of how much it would advance for delinquencies.

Servicer advances are not common in Mexico but they are standard practice in other markets such as US RMBS. Moody's believes that FOVISSSTE's advances strengthen the transactions' cash flows and mitigate any operational delays in receiving the payroll deducted mortgage payments from employers. However, the TFOVIS transaction documents do not call for servicer advances, which introduces some uncertainty with respect to how FOVISSSTE calculates and accounts for such advances in the collections reports.

The second reporting inconsistency is that the collections reports show that FOVISSSTE has been netting and withholding its servicing fee from the amount that it deposits to the trust. This resulted in a duplicate servicing fee payment instruction, because the trustee already accounted for these fees by distributing them from the trust account in accordance with the trust agreements. After Moody's raised this issue, ACFIN published revised historical collections reports to undo this incorrect netting of the servicing fee payment, resulting in instructions to FOVISSSTE to make higher deposits. This error became recently apparent once FOVISSSTE started making deposits in accordance with ACFIN's collections report instructions. The impact of this duplicate servicing fee payment instruction is unclear since, according to FOVISSSTE, it is not actually deducting its servicing fee from the totals it deposits to the trust despite the netting calculation in the collections reports.

The third reporting inconsistency is that for some transactions, ACFIN did not publish the collections report for the month immediately after the pool's cut-off date. This has distorted our understanding of the cumulative amounts that FOVISSSTE should have deposited into each of the trusts since the transactions' closing dates. It is key to have a clear understanding of this when trying to determine the combined impact of the reporting issues highlighted in this press release. Since FOVISSSTE had not been depositing collections according to ACFIN's, it is possible that FOVISSSTE has been depositing these amounts that ACFIN did not account for. However, this will only be determined once a full reconciliation of the historical collections reports is prepared.

The last issue (which was disclosed to the market earlier this year) is that prior to January 2011, FOVISSSTE had inadvertently been over-depositing amounts it considered to be a portion of the employers' 5% contribution on the mortgages. ACFIN has indicated in the collections reports that a portion of the monthly collections since January 2011 have been returned to FOVISSSTE as partial reimbursement for these excess deposits. However, whether FOVISSSTE actually received these reimbursements is unclear. In any case, it appears that investors have received more money than they would have had this error not occurred. Moody's will assess the combined impact of this issue with the others presented in this press release.

MOODY'S FOCUS DURING THE REVIEW PERIOD

Moody's review will focus on the following:

i. The initiatives that the transaction parties take to resolve the identified reporting issues and improve reporting transparency -- in particular:

- whether an independent third party will review the TFOVIS collections reports data and FOVISSSTE's collections and remittance processes

- the results of any such review (including a review of any revised historical collections reports)

- whether FOVISSSTE deposited into the trust account more or less money than it should have as a result of the reporting problems

ii. Ongoing discussions with the trustee (HSBC) and the Common Representative (Deutsche Bank), to understand the steps that will be taken to validate the quality of the collections report data

iii. Whether the parties will amend the transactions' documents to detail the servicer advances that FOVISSSTE is currently making -- this would improve the transparency of the calculation of the advances

In the meantime, Moody's maintains Aaa.mx (sf) / Baa1 (sf) ratings on the affected certificates, albeit on review, due to the following mitigating factors:

i. FOVISSSTE's incentive to perform its duties as servicer given its role as a Mexican government-related institution with a social mission to alleviate the housing shortage by granting mortgages to primarily low-income borrowers

ii. FOVISSSTE's strong alignment of interests with investors, given its ownership in the residual certificates, which represents at least 28% of the securitized pool balance of each transaction (note that FOVISSSTE cannot sell its residual ownership interest)

iii. FOVISSSTE's financial stability, given its status as a government-related institution and its predominance as the second largest mortgage originator in Mexico

iv. The transactions' full turbo waterfalls, which capture all excess spread; all monthly collections remaining after covering trust fees and Class A certificate coupon payments are used to amortize the certificates until paid in full

v. The low level of 90+ day delinquencies -- less than 5% of the current pool balances -- and strong credit enhancement, with overcollateralization levels exceeding 28% for all deals.

RATING METHODOLOGY

The principal methodology used in this rating was "Moody's Approach to Monitoring Residential Mortgage-Backed Securitizations in Mexico" published August 2009. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.

Moody's National Scale Ratings (NSRs) are intended as relative measures of creditworthiness among debt issues and issuers within a country, enabling market participants to better differentiate relative risks. NSRs differ from Moody's global scale ratings in that they are not globally comparable with the full universe of Moody's rated entities, but only with NSRs for other rated debt issues and issuers within the same country. NSRs are designated by a ".nn" country modifier signifying the relevant country, as in ".mx" for Mexico. For further information on Moody's approach to national scale ratings, please refer to Moody's Rating Implementation Guidance published in August 2010 entitled "Mapping Moody's National Scale Ratings to Global Scale Ratings".

REGULATORY DISCLOSURES

The Global Scale Credit Ratings for the following issuers/deals that are issued by one of Moody's affiliates outside the EU are considered EU Qualified by Extension and therefore available for regulatory use in the EU. Further information on the EU endorsement status and on the Moody's office that has issued a particular Credit Rating is available on www.moodys.com.

FOVISSSTE - TFOVIS 09U

FOVISSSTE - TFOVIS 09-2U

FOVISSSTE - TFOVIS 09-3U

FOVISSSTE - TFOVIS 10U

FOVISSSTE - TFOVIS 10-2U

FOVISSSTE - TFOVIS 10-3U

FOVISSSTE - TFOVIS 10-4U

FOVISSSTE - TFOVIS 11-U

FOVISSSTE - TFOVIS 11-2U

FOVISSSTE - TFOVI E11U

For ratings issued on a program, series or category/class of debt, this announcement provides relevant regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series or category/class of debt or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this announcement provides relevant regulatory disclosures in relation to the rating action on the support provider and in relation to each particular rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides relevant regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on www.moodys.com.

Moody's considers the quality of information available on the rated entity, obligation or credit satisfactory for the purposes of issuing a rating.

Moody's adopts all necessary measures so that the information it uses in assigning a rating is of sufficient quality and from sources Moody's considers to be reliable including, when appropriate, independent third-party sources. However, Moody's is not an auditor and cannot in every instance independently verify or validate information received in the rating process.

Please see Moody's Rating Symbols and Definitions on the Rating Process page on www.moodys.com for further information on the meaning of each rating category and the definition of default and recovery.

Please see ratings tab on the issuer/entity page on www.moodys.com for the last rating action and the rating history. The date on which some ratings were first released goes back to a time before Moody's ratings were fully digitized and accurate data may not be available. Consequently, Moody's provides a date that it believes is the most reliable and accurate based on the information that is available to it. Please see the ratings disclosure page on our website www.moodys.com for further information.

Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal entity that has issued the rating.

Third Contact:

Joel Sanchez Hernandez
Analyst
Structured Finance Group
Moody's de México, SA de CV
Paseo de las Palmas No. 405 -502
Lomas de Chapultepec
Mexico City, DF 11000
Mexico
JOURNALISTS: 001-888-779-5833
SUBSCRIBERS:52-55-1253-5700

Karen Ramallo
Asst Vice President - 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

Maria Muller
Senior Vice President
Structured Finance Group
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Releasing Office:
Moody's de Mexico S.A. de C.V
Ave. Paseo de las Palmas
No. 405 - 502
Col. Lomas de Chapultepec
Mexico, DF 11000
Mexico
JOURNALISTS: 001-888-779-5833
SUBSCRIBERS:52-55-1253-5700

Moody's places on review for possible downgrade ten TFOVIS RMBS issued by FOVISSSTE in Mexico
No Related Data.
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