Golden Credit Card Trust (Series )

Transcription

1 Presale: Golden Credit Card Trust (Series ) June 14, 2018 This presale report is based on information as of June 14, The ratings shown are preliminary. This report does not constitute a recommendation to buy, hold, or sell securities. Subsequent information may result in the assignment of final ratings that differ from the preliminary ratings. Preliminary Rating Class Preliminary rating(i) Interest rate(ii) Preliminary amount (mil. $)(iii) Credit support (%)(iv) A AAA (sf) Floating TBD 6.50 B NR Fixed TBD 2.00 C NR Fixed TBD 0.00 PRIMARY CREDIT ANALYST Sanjay Narine, CFA Toronto + 1 (416) SECONDARY CONTACT Kelly R Luo New York (1) (i)the rating on the class A notes is preliminary and subject to change at any time. (ii)the interest rates will be determined on the pricing date. (iii)the class A notes will be denominated in U.S. dollars. The class B and C notes will be denominated in Canadian dollars. (iv)the credit support percentage is calculated after converting the class A notes to Canadian dollars from U.S. dollars using the swap exchange rate. In addition, the series notes will benefit from a dynamic reserve account, which will trap available excess spread incrementally if the series' three-month average excess spread declines below 4.00%. NR--Not rated. TBD--To be determined. Profile Expected closing date June 21, Expected payment date May 17, Prescription date (legal maturity) May 15, Interest payment date Collateral Issuer Seller/servicer/administrative agent and swap counterparty Indenture trustee Issuer trustee Custodian For the class A notes, the 15th of each month (or the following business day) beginning July 16, For the class B and C notes, semiannually on the 15th of each May and November (or the following business day) each year beginning Nov. 15, If an amortization event occurs, interest on the class B and C notes will be due monthly rather than semiannually. An ownership interest in a revolving pool of Canadian dollar-denominated MasterCard and VISA credit card receivables generated by personal and small business accounts originated by Royal Bank of Canada. Golden Credit Card Trust. Royal Bank of Canada. CIBC Mellon Trust Co. Computershare Trust Co. of Canada. BNY Trust Co. of Canada. June 14,

2 Profile (cont.) Lead underwriter RBC Capital Markets LLC. Rationale The preliminary 'AAA (sf)' rating assigned to Golden Credit Card Trust's credit card receivables-backed floating-rate series class A notes reflects: - Our view of the proposed 6.5% credit support provided by the subordinated class B and C notes, which we believe is sufficient to withstand the simultaneous stresses we apply to our 4.0% base-case loss rate, 30.0% base-case payment rate, and 15.0% base-case yield assumptions for the collateral. In addition, we used stressed excess spread and purchase rate assumptions to assess whether, in our opinion, the proposed credit support is commensurate with the preliminary 'AAA (sf)' rating on the class A notes. All of the stress assumptions outlined above are based on our current criteria and assumptions for Canadian credit card securitizations (see "General Methodology And Assumptions For Rating Canadian Credit Card ABS" published March 22, 2012). - Our expectation that under a moderate ('BBB') stress scenario, all else being equal, our rating on the class A notes will remain within one rating category of the assigned preliminary 'AAA (sf)' rating in the next 12 months based on our credit stability criteria (see "Methodology: Credit Stability Criteria," published May 3, 2010). - Our view that the 7% minimum seller's interest is sufficient in our stress scenarios to absorb dilutions, or noncash reductions, in the receivables, including potential set-off rights of cardholders against deposits with the seller but excluding potential set-off rights resulting from judgments or settlements under certain class action proceedings. - Our view of the credit risk that is inherent in the collateral loan pool based on our economic forecast, the master trust portfolio's historical performance, and the collateral characteristics. - Our view of Royal Bank of Canada's (RBC; AA-/Negative/A-1+) servicing experience and our opinion of its account origination, underwriting, account management, collections, and general operational practices. - Our expectation of the timely interest and ultimate principal payments by the May 15, 2023, prescription date, based on stressed cash flow modeling scenarios using assumptions that are commensurate with the preliminary 'AAA (sf)' rating. - The transaction's proposed payment structure, cash flow mechanics, and legal structure. - The swap agreement provided by RBC, which mitigates the currency and interest rate risk between the Canadian dollar-denominated collateral and U.S. dollar-denominated class A notes. In rating this transaction, we will review the swap documentation for consistency with our counterparty criteria for 'AAA' rated transactions (see "Counterparty Risk Framework Methodology And Assumptions" published June 25, 2013). Changes From The Series Transaction Series is a three-year floating-rate transaction whereas series is a five-year floating-rate. Otherwise, the transaction structure is the same, including the issuing entity, June 14,

3 eligible accounts and receivables, payment priority, collection and allocation mechanics, early amortization events, and events of default. Since series was issued, collateral performance has remained steady, and there have been no material changes in collateral performance. Transaction Overview The trust is structured as a master note trust that issues notes through separate series. For all series of notes issued by the trust after November 2014, including series notes, the capital structure has a senior/subordinated structure consisting of the class A, B, and C notes. For , interest on the class A notes will be due on the 15th of each month (or the next business day). Interest on the subordinated class B and C notes will be due semiannually on the 15th of each May and November (or the next business day). If an amortization event occurs, interest on the class B and C notes will be due monthly rather than semiannually. The series notes are three-year notes with an expected payment date of May 17, The series notes may begin receiving principal before the expected payment date if an amortization event triggers early amortization (see the Principal Payments And The Prescription Date section below). The preliminary 'AAA (sf)' rating on the class A notes addresses our expectation that timely interest and ultimate principal will be paid by the prescription date, May 15, 2023, which is 24 months following the expected payment date. On the closing date, the trust will purchase from RBC, the seller, an undivided co-ownership interest in a revolving pool of VISA and MasterCard credit card receivables generated by designated personal and small-business credit card accounts (the series ownership interest). The trust will finance its ownership interest by issuing the series notes, which will be secured by, and with recourse limited to, the series ownership interest. The trust currently has 12 other series outstanding, including the enhancement series. The enhancement series was issued on Nov. 21, 2014, to provide additional credit enhancement to all series issued before Nov. 21, 2014 (only series is outstanding as of June 2018). Each series of notes issued after Nov. 21, 2014, including series , has recourse limited to the related ownership interest. Legal Structure The trust has a structure consistent with our criteria for bankruptcy-remote special-purpose entities (see "Structured Finance: Asset Isolation And Special-Purpose Entity Methodology," published March 29, 2017). In rating this transaction, we will review the legal matters and opinions that we believe are relevant to our analysis as outlined in our criteria. Credit Support According to the transaction documents, the class A notes will benefit from 6.50% credit enhancement provided by the subordinated class B and C notes and from deposits made to the reserve account. The required reserve account amount will be zero at closing and will increase incrementally if the series' three-month average excess spread (yield over transaction expenses and defaults) is less than 4.00%. The required reserve amount will be funded through excess spread up to the amount determined according to table 1. June 14,

4 Table 1 Required Reserve Amount Excess spread % of initial invested amount Less than or equal to 1.50% 5.00 Greater than 1.50% to less than or equal to 2.50% 2.00 Greater than 2.50% to less than or equal to 3.50% 1.50 Greater than 3.50% to less than 4.00% 1.00 Greater than or equal to 4.00% 0.00 Although the transaction documents provide that the reserve account will be available for the class A notes, there is no benefit in our 'AAA' cash flow analysis because we assume excess spread immediately declines below zero after closing and triggers amortization (see the Amortization events section below). The Swap Agreement The class A notes will benefit from a cross-currency interest rate swap, with RBC as the initial counterparty. The swap is structured so that the notional amount is equal to the class A notes' outstanding U.S. dollar principal balance. Under the swap, the trust will pay RBC a fixed interest rate in Canadian dollars based on the Canadian dollar equivalent of the U.S. dollar swap notional amount (determined by using the exchange rate established on the transaction's closing date). In return, RBC will pay the trust a U.S. dollar-denominated floating interest rate equal to the monthly coupon on the class A notes. On dates when principal payments are scheduled to be made on the class A notes, the trust will pay the available collections allocated to series , in Canadian dollars, to RBC. In return, RBC will pay the trust the U.S. dollar equivalent (determined by using the exchange rate established on the transaction's closing date) of the payments received from the trust. Due to the swap, the class A notes are Canadian dollar-denominated fixed-rate obligations, which is how we modeled them in our cash flow analysis. If the swap is terminated, termination payments owed to the swap counterparty, if any, will be paid only after interest and principal payments have been made to the series notes. In rating this transaction we will review the swap documentation for consistency with our counterparty criteria (see "Global Derivative Agreement Criteria," published June 24, 2013, and "Counterparty Risk Framework Methodology And Assumptions," published June 25, 2013). Payment Priority And Allocations In this transaction, finance charges, losses, and principal receivable collections are allocated separately to each series' co-ownership interest. The finance charge and principal collections are grouped together in a series-specific distribution account, where these funds are deposited, and are distributed per the payment priority (see table 2). In cases where the sum of the principal allocation percentages for each series exceeds 100%, principal will be allocated pro rata based on the series' principal allocation percentage divided by the sum of the principal allocation percentage for all series. June 14,

5 Interest Payments Interest on the class A notes will accrue at a floating rate based on the principal amount outstanding and will be payable on the 15th of each month (or the next business day) beginning July 16, Interest on the class B and C notes will accrue at a fixed rate on the principal amount outstanding and will be payable semiannually on the 15th of each May and November (or the next business day) each year beginning Nov. 15, Interest payable to the class B and C notes will be due monthly if an amortization event is triggered. Principal Payments And The Prescription Date The revolving period for the notes will end at least one month before the expected payment date, at which point the accumulation period will begin as long as no early amortization event has occurred. During the accumulation period, principal collections allocated to the series will be retained in the distribution account and will accumulate until May 17, 2021, the expected payment date, at which point the series notes are scheduled to receive a single payment for their full outstanding note balance. The accumulation period must begin no later than April 17, 2021, but can begin on an earlier date the servicer specifies. In deciding whether to specify an earlier accumulation commencement day, the servicer will determine if the expected availability of collections to the trust, based on the principal payment rates for the collateral and the principal payment requirements of other series in their accumulation or amortization periods, will be sufficient to repay the series notes on the expected payment date. We believe the one-month minimum accumulation period reduces the negative carry risk (the difference between the reinvestment rate on the amounts accumulated in the distribution account and the coupon on the notes). In addition, at least three months before the accumulation period begins, the issuer will begin to trap 75 basis points of the initial invested amount from the available excess spread to mitigate negative carry risk. If an amortization event occurs, any funds in the distribution account, including any principal collections accumulated, will be paid directly to the noteholders--first to class A, then B, and then C. Although interest will then be due monthly on the class B and C notes, all available collections (interest and principal) will first be used to reduce the class A note principal. The noteholders are entitled to receive principal and interest until the prescription date as long as an invested amount of ownership interest remains. The preliminary 'AAA (sf)' rating on the class A notes addresses our view that timely interest and ultimate principal will be paid by the prescription date, May 15, The noteholders could be repaid earlier or later than the expected payment date if an amortization event occurs. The noteholders could also be repaid later than the expected payment date if the trust fails to accumulate sufficient principal collections during the accumulation period. When assigning a preliminary rating to the class A notes, we assumed in our cash flow runs that the transaction will miss its expected payment date, triggering an amortization event (see the Amortization events section below). Payment Priority All amounts deposited into the series' distribution account are used to pay the swap counterparty and the noteholders in a single cascade waterfall covering interest payments, principal payments, and expenses in a specified priority (see table 2). On a distribution day when the trust makes any interest or principal payments from the distribution account to the swap counterparty, the swap June 14,

6 counterparty will make its required interest and principal payments (in U.S. dollars) to the class A note liquidation account on that same day. The trust will then withdraw from the class A note liquidation account the U.S. dollar amounts to be paid to the class A noteholders. Table 2 Finance Charge And Principal Collections Priority Payment 1 Expenses and fees to the transaction participants, including the indenture trustee, issuer trustee, custodian, independent auditor, and replacement servicer. 2 Canadian dollar-denominated fixed-rate interest payments owed to the swap counterparty (in return for the U.S. dollar floating-rate interest on the class A notes). 3 Canadian dollar-denominated principal payments owed to the swap counterparty (in return for the U.S. dollar-denominated class A notes' principal). 4 Class B noteholders' interest. 5 Class B noteholders' principal. 6 Class C noteholders' interest. 7 Class C noteholders' principal. 8 Additional funding expenses paid to the indenture trustee, administrator, and other third parties, including any swap termination payments owed to the swap counterparty if the swap is terminated. During the accumulation period, principal collections deposited into the distribution account will not be available for payment in the waterfall and will be retained in the account until principal is required to be paid to the noteholders. During the amortization period, the class B and C noteholders will not receive any interest or principal until the class A noteholders have been repaid in full. Amortization events An amortization period will begin on the business day immediately following an amortization event. Amortization events include: - The seller or servicer fails to make any payment, transfer, or deposit required by the transaction documents. - The seller or servicer breaches a covenant, representation, or warranty. - Bankruptcy or insolvency of the seller or any successor servicer. - A servicer termination event occurs. - The three-month average excess spread percentage for any monthly period is less than zero. - The three-month average total payment rate is less than 10%. - The note principal balance is not paid in full by the expected payment date. - The pool balance is less than the required pool amount, and such deficiency is not remedied within 10 days. - During the accumulation period, the sum of the available finance charges allocated to the series plus the available reserve amount is less than the sum of the funding costs and additional funding expenses and the series allocation of pool losses. June 14,

7 - An event of default occurs and the notes are accelerated. The noteholders may waive certain events of default if at least two-thirds of the class A, B, and C noteholders consent. If the noteholders waive an event of default or vote to liquidate the collateral following an event of default, we would evaluate the effect on the assigned ratings at that time. Originator/Servicer Overview RBC is the originator and servicer of the trust's portfolio of credit card accounts. RBC operates its Canadian credit card business through its digital payments and cards, a part of RBC's personal and commercial banking segment. RBC has subcontracted responsibility for daily reporting, processing account information, and billing for all of its credit cards to Total System Services Inc. ('BBB-/Stable'; see "Summary: Total System Services Inc.," published May 1, 2017). We consider RBC's business position "strong" (as defined in our criteria, "Banks: Rating Methodology And Assumptions," published Nov. 9, 2011), reflecting its solid franchise, favorable strategy, and dominant Canadian market positions. The bank also has a "strong" risk position, which reflects more favorable asset quality metrics than some of its domestic peers and less volatility in its capital markets business than its like-sized international peers. We consider the capital and earnings position to be "adequate", funding to be "average", and its liquidity position to be "adequate" (see "Royal Bank of Canada," published June 20, 2017). Collateral Overview The series notes' collateral consists of an undivided co-ownership interest in a revolving pool of credit card receivables generated by specified personal and small business MasterCard and VISA credit card accounts. The receivables, denominated in Canadian dollars, comprise all interest charges, annual membership fees, interchange, and certain other fees, as well as all amounts charged by cardholders for merchandise and services, amounts advanced to cardholders, and all other cardholder and account fees. Collections on the receivables, including recoveries from defaulted receivables, will be available to pay the noteholders' interest and principal payments. Asset Pool Collateral Characteristics As of March 31, 2018, the trust's pool consisted of C$10.9 billion in total receivables (from approximately 9.9 million accounts) with the following characteristics: - An average account balance of C$1,097; - Of the accounts, 74% had a credit or zero balance; - For accounts with a positive balance, the average balance was C$4,195; - An average credit limit of C$7,018; - A utilization rate of 16%; - Receivables from accounts seasoned at least five years accounted for 94.5% of the pool, and receivables from accounts seasoned at least 10 years accounted for 67.3% of the pool; - The top five geographic concentrations were Ontario (36.5% of receivables), British Columbia (18.3%), Alberta (16.2%), Quebec (13.2%), and Manitoba (4.1%); and June 14,

8 - Obligors whose FICO-equivalent score was at least 660 represented 83.0% of the receivables. Obligors whose FICO-equivalent score was 700 or higher represented 66.9% of the receivables. Collateral Historical Performance We compared Golden Credit Card Trust's performance with our Canadian Credit Card Quality Index (CCQI; see table 3). Overall, the receivables in this pool exhibit a higher payment rate, lower loss rate, and lower delinquencies than the Canadian CCQI, and the yield is broadly in line with the index. The Canadian CCQI tracks the performance of approximately C$49.2 billion in credit card receivables from eight major Canadian trusts: Canadian Credit Card Trust II, CARDS II Trust, Eagle Credit Card Trust, Evergreen Credit Card Trust, Glacier Credit Card Trust, Golden Credit Card Trust, Master Credit Card Trust II, and Trillium Credit Card Trust II. Table 3 Golden Credit Card Trust Collateral Performance Canadian CCQI Average for three months ended Average for three Golden Credit Card Trust months ended Average for the year ended Dec. 31 March 2018 March Avg. principal receivables outstanding (bil. C$)(i) Annualized portfolio yield (%) Avg. monthly payment rate (%) Delinquencies of 30 days or more (%)(ii) Annualized net losses (%) (i)the trust's average collateral performance results for the years ended Dec. 31 is calculated using the beginning monthly pool balance. (ii)delinquencies are not averaged and are reported at the end of the reporting period. CCQI--Credit Card Quality Index. Loss Performance Our base-case loss rate assumption is 4.0%, which is a forward-looking view and incorporates our Canadian economic forecast. Our 'AAA' stressed annualized peak loss assumption of 21.38% is at the lower end of the 21%-30% range that we apply for typical Canadian credit card pools but well below the 33% floor that we established for the U.S. benchmark pool in our criteria. Our assumption reflects that net losses for the trust are lower than peers' and have trended below the CCQI. For the three months ended March 2018, the net loss rate averaged 2.4%. Although we recognize that higher unemployment in Canada's oil-producing regions (largely Alberta, Saskatchewan, and Newfoundland and Labrador) could result in a moderate rise in delinquencies and charge-offs of Canadian credit card receivables, we believe that the pool's geographic diversification will likely mitigate the overall impact on the trust's performance because receivables from accounts in these regions only represent approximately 21.4% of receivables outstanding as of March In our cash flow analysis, we assume that loss rates rise to the stress levels within 12 months June 14,

9 following the commencement of the amortization period for the 'AAA' and 'A' scenarios and within 18 months for the 'BBB' scenario. Chart 1 Yield Performance Our base-case yield assumption on the pool is 15%. Before October 2009, the trust's total yield ranged from 12.0%-15.0%. In October 2009, the trust's documents were amended to include interchange generated by the designated accounts in the finance charge collections. Since then, total yield has increased, to nearly 22.2% for the three months ended March 2018 from an average of just over 15.0% in 2009 (see chart 2). Interchange fees are included in the trust's collections; however, because we believe interchange may not be available to the trust if the card lender becomes insolvent, we generally do not assign any credit to interchange in our yield assumptions for the higher rating categories. As a result, our base-case yield assumption is significantly below the current yield. In our 'AAA' cash flow analyses, we assume an immediate decline in the stressed portfolio yield due to restrictive pricing regulations and competitive pressures, including low introductory and promotional rates, which would suppress yield when amortization begins. Our 'AAA' stressed yield of 10% is equal to 67% of the base case, which is a smaller haircut to the base case than for many other issuers because, in our opinion, this pool has a large portion of high-quality prime cardholders. We believe this pool is less likely to experience a sharp increase in delinquencies because of the high portion of prime accounts, resulting in less volatility in stressed yield than pools that include a higher portion of nonprime accounts. June 14,

10 Chart 2 Payment Rate Performance Our base-case total payment rate assumption for the trust is 30.0%. In our stress scenarios, we assume that the number of convenience users in the pool declines before the first month of an amortization scenario and the portion of revolvers increases, causing payment rates to sharply decline. Therefore, our base-case assumption is well below the actual payment rates, which averaged 47.5% for the three months ended March When modeling all of our rating scenarios, we assume that payment rates immediately decrease to the stressed level. June 14,

11 Chart 3 Purchase Rate The purchase rate is the rate at which new receivables are created and transferred to the trust as cardholders use their credit cards to make purchases or cash advances. The transfer of new receivables affects the level of principal receivables in the trust and the monthly collections available to repay the notes. When rating credit card asset-backed securities, we consider the originator's issuer credit rating (ICR) in our purchase rate assumptions; in this case, RBC is rated AA-/Negative/A-1+. The purchase rate assumptions reflect our view of the originator's ability to continue generating and transferring receivables to the trust. In our opinion, the lower the ICR on the originator, the weaker the seller's ability to generate and transfer receivables to the trust on an ongoing basis. Accordingly, the purchase rate assumption declines as ratings migrate to lower rating categories (see "Revised Purchase And Payment Rate Assumptions For U.S. Credit Card ABS" published Sept. 14, 2011). With our current 'AA-' rating on RBC, we assume a 3.25% purchase rate for the preliminary 'AAA (sf)' rated notes in the pool. Under our criteria, any negative rating action on RBC could warrant a reduction in our purchase rate assumption. To assess the potential rating impact on the class A notes if we lowered the rating on RBC, we also considered a scenario with a 3.00% purchase rate, which is the maximum that could be applied under our criteria for originators rated in the 'A' category. Based on this scenario, we do not believe a downgrade on RBC to the 'A' category would affect our preliminary 'AAA (sf)' rating on the class A notes. June 14,

12 Dilution Analysis Under the transaction's terms, the minimum seller's interest will equal at least 7% of the invested amount to cover noncash reductions in the principal receivables balance. We reviewed the trust's monthly fraud and return data, then staggered dilution that occurred during the 30-, 60-, and 90-day cycles, and applied a 'AAA' multiple to the base-case dilution rate to derive the dilution coverage level that we believe is commensurate with the assigned preliminary 'AAA (sf)' rating. Dilution, which we measured as a percentage of the outstanding receivables, typically runs slightly higher in portfolios with high rates of new purchases compared with portfolios with more revolvers. In addition, we believe the minimum seller's interest of 7% will mitigate any potential set-off risk against deposits cardholders have with the seller that may arise if the seller becomes insolvent. The seller is currently party to certain legal proceedings related to their credit card operations. In the event of any final judgment or settlement under these proceedings, cardholders may have the right to set-off these amounts against their outstanding credit card receivables. We are monitoring further developments in this matter and will evaluate and determine the potential rating impact, if any, on the notes, taking into account the mitigating factors such as the seller's financial strength and the available seller's interest in the trust at the time of the announcement. S&P Global Ratings' Rating Scenarios We applied various stresses when assigning our preliminary 'AAA (sf)' rating to the series class A notes (see table 4; for more information on our assumptions for this transaction and our current criteria, see, "General Methodology And Assumptions For Rating Canadian Credit Card ABS," published March 22, 2012, U.S. Credit Card Securitizations: Methodology And Assumptions, Aug. 24, 2017") Table 4 S&P Global Ratings' Rating Scenarios Scenario Net losses(i) Total payment rate (ii) Yield (iii) Purchase rate(ii) S&P Global Ratings' base-case assumption (%) N/A S&P Global Ratings' 'AAA' stress assumption (%) 'AAA' multiple/% of S&P Global Ratings' base-case assumption x N/A (i)in the 'AAA' rating scenario, losses rise to the stressed multiple over 12 months. (ii)the total payment and purchase rates start at the stressed level in the first month of the cash flows. (iii)in the 'AAA' rating scenarios, yield starts at the stressed level in the first month of the cash flows. N/A--Not applicable. Sensitivity Analysis Our ratings incorporate credit stability as one of several factors that we use to determine an issuer's creditworthiness (see "Methodology: Credit Stability Criteria" published May 3, 2010). Accordingly, we ran sensitivity analyses to determine the notes' credit stability during periods of moderate economic stress. June 14,

13 Based on our rating stability definition, 'AAA' ratings that we assign to a new class of credit card receivables-backed notes signify that, in our opinion, we do not expect the ratings on the notes to fall more than one rating category within 12 months of the rating assignment under moderate stress conditions. To test whether the preliminary 'AAA (sf)' rating we assigned to the class A notes would be vulnerable to a downgrade of more than one category in a moderate ('BBB') stress scenario, we ran sensitivity analyses assuming that the pool's base-case loss rate would increase to 2.38x the current base-case loss rate, or to 8.50%-10.50% from 3.00%-5.00%. In this scenario, we believe that our preliminary 'AAA (sf)' rating on the notes wouldn't be lowered more than one rating category within the next 12 months based on the 6.50% credit support available to the class A notes. Related Criteria - Criteria - Structured Finance - ABS: U.S. Credit Card Securitizations: Methodology And Assumptions, Aug. 24, Legal Criteria: Structured Finance: Asset Isolation And Special-Purpose Entity Methodology, March 29, Criteria - Structured Finance - General: Ratings Above The Sovereign - Structured Finance: Methodology And Assumptions, Aug. 8, Criteria - Structured Finance - General: Methodology: Criteria For Global Structured Finance Transactions Subject To A Change In Payment Priorities Or Sale Of Collateral Upon A Nonmonetary EOD, March 2, Criteria - Structured Finance - General: Global Derivative Agreement Criteria, June 24, Criteria - Structured Finance - General: Criteria Methodology Applied To Fees, Expenses, And Indemnifications, July 12, General Criteria: Global Investment Criteria For Temporary Investments In Transaction Accounts, May 31, Criteria - Structured Finance - ABS: General Methodology And Assumptions For Rating Canadian Credit Card ABS, March 22, Criteria - Structured Finance - General: Standard & Poor's Revises Criteria Methodology For Servicer Risk Assessment, May 28, 2009 Related Research - Canadian Credit Card Quality Index: Canadian Issuers Continue to Look South Of The Border, March 21, Royal Bank of Canada, June 20, Global Structured Finance Scenario And Sensitivity Analysis 2016: The Effects Of The Top Five Macroeconomic Factors, Dec. 16, November 2016 Shelf Review: U.S. And Canadian Bank Credit Card ABS, Nov. 14, 2016 In addition to the criteria specific to this type of security (listed above), the following criteria June 14,

14 articles, which are generally applicable to all ratings, may have affected this rating action: "Post-Default Ratings Methodology: When Does Standard & Poor's Raise A Rating From 'D' Or 'SD'?," March 23, 2015; "Global Framework For Assessing Operational Risk In Structured Finance Transactions," Oct. 9, 2014; "Methodology: Timeliness of Payments: Grace Periods, Guarantees, And Use of 'D' And 'SD' Ratings," Oct. 24, 2013; "Counterparty Risk Framework Methodology And Assumptions," June 25, 2013; "Criteria For Assigning 'CCC+', 'CCC', 'CCC-', And 'CC' Ratings," Oct. 1, 2012; "Methodology: Credit Stability Criteria," May 3, 2010; and "Use of CreditWatch And Outlooks," Sept. 14, June 14,

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