Title
BSP Regulations on Asset-Backed Securities
Law
Bsp Circular No. 185
Decision Date
Dec 8, 1998
BSP Circular No. 185 establishes regulations for the origination, issuance, sale, servicing, and administration of asset-backed securities by banks and non-banks with quasi-banking functions, ensuring compliance with strict documentation, management oversight, and investor disclosure requirements.
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Key Definitions

  • Assets: Loans or receivables on originator's books prior to securitization, including mortgage, consumption, trade, lease, credit card receivables.
  • Asset-Backed Securities (ABS): Certificates issued by the Special Purpose Trust (SPT) representing undivided interest in Asset Pool.
  • Asset Pool: Identified, self-amortizing assets conveyed to the SPT.
  • Clean-up Call: Option for Seller to repurchase remaining assets when balance falls to 10% or less.
  • Credit Enhancement: Legally enforceable schemes enhancing ABS marketability and investor payment probability.
  • Guarantor: Entity guaranteeing repayment upon borrower default.
  • Investible Funds: Collection proceeds not yet distributed to investors.
  • Issuer: The Special Purpose Trust issuing ABS.
  • Originator: Entity assembling loans or receivables into a pool.
  • Residual Certificates: Claims on remaining Asset Pool value after all ABS holders are paid.
  • Seller: Entity conveying assets to SPT.
  • Servicer: Entity collecting payments and remitting to Issuer.
  • Special Purpose Trust (SPT): Trust created solely to issue/administer ABS.
  • Trustee: Entity administering the SPT.
  • Underwriter: Entity distributing and selling ABS.

Board Approval and Management Oversight

  • Securitization program requires board approval.
  • Program must integrate into corporate strategic plan.
  • Board ensures securitization aligns with approved program.

Application Requirements and Documentation

  • Must submit:
    • Trust Indenture detailing asset conveyance and ABS features.
    • Prospectus with ABS class details, asset descriptions, cash flow assumptions, credit enhancement.
    • Specimen application forms and certificates showing terms and required disclosures.
  • Trust indenture includes servicing and underwriting agreements as annexes.

Minimum Features of ABS

  • Pre-numbered, printed on security paper.
  • Signed and authenticated by Trustee.
  • Transferable by endorsement, with transfers recorded in Trustee’s books.
  • Minimum denomination: ₱10,000.

Mandatory Disclosures

  • ABS do not represent deposits or liabilities of originator, servicer, or trustee.
  • Not insured by Philippine Deposit Insurance Corporation (PDIC).
  • Investment involves risk; trustee does not guarantee capital value or asset collectibility.
  • Investors must acknowledge understanding of disclosures.

True Sale and Asset Conveyance

  • Conveyance must be a true sale with assets removed from Seller’s books, except residual certificates.
  • Seller has no obligation to repurchase or substitute assets except in breach or revolving structures.
  • No obligation to maintain collateral coverage ratio except in revolving structures.
  • True sale requires assets isolated from Seller, trustee’s rights to pledge or exchange, and no Seller control.
  • Underwriting and conveyance expenses paid by Originator/Seller until assets conveyed.

Representations and Warranties

  • Must be clear, explicit, reflecting verifiable facts at sale.
  • Do not cover future creditworthiness or SPT performance.
  • Breach claims require good faith negotiation, proof burden on claimant, damages limited to actual loss, written notice.
  • BSP to be notified if damages are paid for breaches.

Due Diligence and Third Party Review

  • Independent due diligence review agreed by Seller and issuer before asset sale.

Roles of Originator, Seller, Trustee, and Servicer

  • Seller may also be Originator and Servicer.
  • Seller delivers all original asset documents to Trustee.
  • Trustee must be a licensed bank trust department.
  • Trustee manages Asset Pool, protects assets, reviews performance quarterly, reports to investors.
  • Trustee initiates legal actions for collection; may delegate to Servicer.
  • Trustee invests Investible Funds only in government or BSP-approved high-grade securities.
  • Trustee can replace Servicer for non-performance.
  • Servicer collects payments, remits to Trustee within a month, reports borrower defaults/adverse developments within 30 days.
  • Servicer needs Trustee’s written approval to waive penalties.

Underwriter Regulations

  • Expanded commercial banks and investment houses to maintain written ABS underwriting policies.
  • Must follow underwriting agreement terms.
  • Underwriters prohibited from dealing in ABS administered by their own trust departments or affiliates.
  • May not extend credit to purchase ABS underwritten by themselves or affiliates.

Guarantor Requirements

  • Must be an entity regularly issuing guarantees.
  • Possess adequate financial capacity; submit semi-annual financials to Trustee.
  • Originator/Seller prohibited from issuing counter-guarantees.

Credit Enhancement Methods

  • Includes standby letters of credit, surety bonds, guarantees from unrelated entities, overcollateralization, spread accounts, subordinated securities, and other BSP-approved methods.
  • Subordinated securities must be sold to third parties not related to Originator/Seller or Trustee, or treated as deposits with capital charges.

Clean-up Call Option

  • Permitted when principal balance falls to 10% or less of original balance.
  • Includes foreclosed/other assets valued at current market price.
  • Exercise does not violate non-recourse or true sale provisions.

Prohibited Activities

  • Seller may not designate its own or affiliate trust departments as Trustee.
  • Directors/officers/employees of Originator/Seller/Servicer prohibited from serving on Trustee’s boards during securitization.
  • No credit facility commitments to Issuer/Trustee in trust indenture.
  • ABS not eligible as collateral for loans from originating bank/NBQB.
  • Trust departments prohibited from purchasing ABS they administer for their own fiduciary accounts.
  • Trustee may not designate subsidiaries or affiliates as Servicer.

Amendment and Reporting

  • Trust indenture amendments require BSP approval.
  • Trustee must submit quarterly securitization reports to BSP within 15 banking days.

Sanctions

  • Violations subject to penalties under Section 37 of Republic Act No. 7653.
  • Circular effective immediately upon issuance.

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