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bonds to the investment community, dealers provide this service. Bonds typically trade
more actively closer to their date of issue. Because bond investors—usually institutional
investors such as pension funds and insurance companies—hold most bonds to maturity,
trading in bonds declines as they draw nearer to their stated maturity date. The issuance
volume of a certain bond, a bond's credit rating and whether it was issued publicly or
privately can also affect liquidity. All ABS and MBS are traded on the dealer-based,
over-the-counter markets so liquidity depends in part on the ability and willingness of
dealers to maintain an inventory, or make a market, in a certain bond.
Benefits of Securitization
Less Expensive, More Broadly Available Credit
The public benefits of securitization are evident in a number of ways. Chief among these
is the contribution of securitization to lower borrowing costs both for individuals and
corporations. The existence of a liquid secondary market for home mortgages increases
the availability of capital to make new home loans. Financial institutions that realize the
full value of their loans immediately can turn around and re-deploy that capital in the
form of a new loan. This is often the most efficient way to raise new funds in the capital
markets and the savings are passed on to the borrower.
Consumers other than homebuyers also benefit from lower borrowing costs.
Securitization can lower a firm's financing costs as well. MBS and ABS are often
designed to carry a higher credit rating than the originating firm would otherwise realize
for other types of bonds. Higher credit ratings mean the security is less risky and
translates into a lower interest rate for the originator as investors do not demand the same
risk premium. The originator passes the savings on to the consumer in the form of lower
lending rates.
Securitization also aids in the geographic dispersion of capital to areas that may
otherwise be deprived of credit options. Traditionally, depository institutions have
provided credit in the areas where they accepted deposits. By securitizing loans,
however, the lender generates capital for new loans that may come from a different
location. This linkage to the capital markets broadens the range of regions where
depository institutions obtain capital to provide credit.
By subjecting the lending decisions of financial institutions to valuation by the capital
markets, securitization also encourages an efficient allocation of capital. Financial
institutions and others who securitize assets depend, of course, on investors. Investors
seek an appropriate return based on a level of risk. If the asset pools are not of a
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sufficient quality, for example, investors will demand a higher interest rate as
compensation. At its most basic level, securitization is the process of isolating risk and
repackaging it for investors. This increases efficiency in the capital market by removing
intermediary steps between investors and the risk they are assuming. A money manager,
for example, may be interested in a mortgage-backed bond that pays interest and
principle on a monthly basis, but not in the debt securities issued by the originator of the
securitized assets.
Securitization reallocates risk at many levels. By shifting the credit risk of the securitized
assets (for a price) to ABS and MBS investors, financial institutions can reduce their own
risk. As the risk level of an individual institution declines, so does systemic risk, or the
risk faced by the financial system overall.
More Options for Investors
As noted above, investors benefit from the legal segregation of the securitized assets.
The segregation protects the payment stream on the MBS and ABS from a bankruptcy or
insolvency. Higher-rated securitized instruments generally offer higher yields than
similar sovereign government issues. The actual size of this yield premium, the yield the
securities pay in excess of similar government securities—will depend on the credit
quality of the assets and the structure of the transaction. Pension funds—which comprise
much of the market for MBS and ABS—pay close attention to this premium as they seek
a wide variety of safe fixed income products with attractive yields. Insurance companies,
money managers and other institutional investors with needs for fixed-income securities
with specific features are also large ABS/MBS investors.
The ability of issuers to vary the terms of securities backed by the same asset pool
through different securitization techniques also makes MBS and ABS attractive to
investors. In a sense, issuers can tailor the coupon, maturity and seniority of a security
according to particular investor's needs. This flexibility not only boosts investor interest
in ABS and MBS, but also contributes to more efficient capital markets by ensuring
investors and money managers have access to the most appropriate securities.
Flexibility for the Originator
Securitization also benefits the financial institution or corporation that originates the
securitized asset. Without securitization, a bank making a home loan usually would hold
that loan on its books, recognizing revenue as payments are made over time. To realize
the value of the loan immediately, the bank can sell the whole loan to another institution,
though this is generally not economical unless the loan is very large. The more efficient
option is to pool similar loans together, as discussed above, and enter into a securitization
transaction.
The process makes even more sense for originators with assets considered illiquid, such
as equipment leases or the balance due on a credit card. The latter comprises an asset
class called credit card receivables that account for approximately 20 percent of
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outstanding ABS. Similar to banks securitizing home loans, credit card companies are
able to use the securitization process to provide more credit and manage their balance
sheets.
Originators realize another benefit from securitization as the transfer of the asset to an
SPV removes it from the firm's balance sheet. This can help the originator improve
certain measures of financial performance such as return-on-assets (ROA). A way to
gauge a firm's efficiency, ROA tells observers how many dollars are earned for every
dollar of assets. Moving an asset off of the balance sheet while simultaneously
increasing income has a positive effect on ROA and demonstrates to investors a more
efficient use of capital. Banks realize a unique advantage from securitization. Removing
loans from their balance sheet can lower regulatory capital requirements, or the amount
and type of capital banks must hold given the size of their loan portfolio, to reflect
lowered risk.
The segregation of assets that takes place in a securitization can also effectively lower the
firm's financing costs. This occurs when the securities issued by the SPV carry a lower
overall interest rate than the originating firm pays on its debt. As the firm receives the
proceeds from the securitization it has, in effect, achieved cheaper financing than might
have been extended to the firm based solely on its own credit rating.
Conclusions
Securitization reflects innovation in the financial markets at its best. Pooling assets and
using the cash flows to back securities allows originators to unlock the value of illiquid
assets and provide consumers lower borrowing costs at the same time. MBS and ABS
securities offer investors with an array of high quality fixed-income products with
attractive yields. The popularity of this market among issuers and investors has grown
dramatically since its inception 30 years ago to $6.6 trillion in outstanding MBS/ABS
today.
The success of the securitization industry has helped many individuals with subprime
credit histories obtain credit. Securitization allows more subprime loans to be made
because it provides lenders an efficient way to manage credit risk. Efforts to curb
“predatory” lending that inhibit the legitimate use of securitization by assigning liability
to the purchaser of a loan or some other means, threaten the success of the beneficial
subprime market. Secondary market purchasers of loans, traders of securitized bonds and
investors are not in a position to control origination practices loan-by-loan. Regulation
that seeks to place disproportionate responsibilities on the secondary market will only
succeed in driving away the capital loan purchasers provide in the subprime market.
I urge Congress to move with great care as it addresses the problem of predatory lending.
The secondary markets are a tremendous success story that has helped democratize credit
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in this country. Well intended, but overly restrictive, regulation in this area could easily
do more harm than good. This is particularly the case when state and local governments
craft disparate anti-predatory lending statutes that place different compliance burdens on
the secondary market. For this reason, the ASF urges this committee to consider
legislation to pre-empt the authority of state and local governments in the area of
predatory lending and to construct a safe harbor from assignee liability for secondary
market participants.
Thank you again for the opportunity to testify today.
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