Structured Finance. Provide Residence PLC. Residential Mortgages / Germany New Issue

Transcription

1 Residential Mortgages / Germany New Issue Final Ratings Credit Linked Notes due 2035 Class Amount (EUR million) Rating CE A+ 250,000 AAA 16% A 45,000,000 AAA 13% B 60,000,000 AA 9% C 49,000,000 A 6% D 34,500,000 BBB 3.5% E 21,500,000 BB 2% Analysts Matthias Neugebauer +44 (0) matthias.neugebauer@fitchratings.com Asina Ajwani +44 (0) asina.ajwani@fitchratings.com Surveillance Antje Mayer antje.mayer@fitchratings.com Summary This transaction is a securitisation of residential mortgages originated in Germany. Fitch Ratings has assigned ratings to the credit-linked notes issued by ( Provide Residence 2002 or the issuer ) as indicated at left. The transaction is synthetic and referenced to a pool of German residential mortgage loans originated by Commerzbank AG ( Commerzbank ). There will be no transfer of the legal title of the mortgages which form the reference portfolio for the notes. Commerzbank will continue to service the loans. The notes are issued by the bankruptcy remote, special purpose vehicle Provide Residence 2002, incorporated in Ireland. The class A+ to E notes are backed by credit-linked certificates of indebtedness ( Schuldscheine ) issued by Kreditanstalt für Wiederaufbau ( KfW ), a German public agency. The certificates will be purchased by Provide Residence 2002 with the proceeds from the notes. The terms and conditions of each certificate of indebtedness will match those of the associated notes (A+ to E), including principal and interest. KfW will sell protection on the reference portfolio held by Commerzbank under a credit default swap ( CDS ). This exposure is transferred to the senior and junior swap counterparties via CDSs and to the issuer via the certificates of indebtedness and finally to the noteholders via the class A+ to E notes. Following a credit event in the reference portfolio and after foreclosure and liquidation proceedings, a realised loss will be determined. Such losses will be borne first by the junior CDS then the notes in reverse order of seniority from class E to A. Cumulative losses exceeding the sum of the notes (A to E) and the junior CDS will be borne by the class A+ notes and the senior CDS counterparty according to a fixed ratio. COMMERZ BANK Originator Servicer (Reference Portfolio) Payment of Losses under Bank Swap Interest Sub Participation KfW Sponsor Payment of Losses Certificates of Indebtedness Cash Proceeds from Notes Interest Sub Participation Payment of Losses Senior Credit Default Swap Counterparty The ratings of the notes are inter alia dependent on Fitch s ongoing view of the credit quality of KfW. Should the agency be of the opinion that KFW s credit quality has deteriorated, the ratings of the notes could be downgraded. SPV Provide- Residence Junior Credit Default Swap Counterparty Class A+ Class A Class B Class C Class D Class E 17th July

2 The ratings of the notes address timely payment of interest and ultimate payment of principal and are based on the quality of the collateral, Commerzbank s underwriting and servicing capabilities and the sound financial and legal structures. Credit enhancement for the class A+ notes will be provided by subordination, which totals 16% and consists of the class A (3%), B (4%), C (3.25%), D (2.3%) and E notes (1.4%) and the junior CDS (2.1). To determine appropriate levels of credit enhancement, Fitch analysed the collateral using its loan-by-loan German mortgage default model (please refer to: German Residential Mortgage Default Model dated 7 September 2001, available at Credit Committee Highlights 1. The portfolio only includes the second ranking loan part (Nachrang) in excess of 60% Loan to Lending Value (LTLV). 2. Realised losses on the mortgages are defined as principal losses only. 3. The portfolio includes an average proportion of investment properties (21.80%), Fitch has increased the default probability in order to account for the increased risk of default. 4. The portfolio does not include any multi-family houses. 5. High WA LTV compared to previous securitised residential mortgage portfolios in Germany. 6. The ratings are based on the credit quality of KfW securitised loans, taking into account prior ranking claims held by Commerzbank or external parties. The portfolio includes interest only (35.3%) as well as repayment mortgages (annuities and instalments, (64.7%). 100% of the interest only loans are linked to life insurance or savings contracts ( Bausparvertraege ), which are pledged to Commerzbank. All loans carry a fixed rate of interest with various reset dates. The loans in the portfolio have all been originated since January 1988 and the weighted average seasoning is approximately 45.6 months. At the cut-off date, all mortgage loans were fully performing. In terms of geographic concentration, the highest regional concentration (using Fitch s geographical divisions), are in the North (27.61%), in the West (25.91%), and in the East of Germany (19.13%). The agency considers the portfolio to be sufficiently diversified. Portfolio Summary (as of March 2002) Proportion of annuity and instalment 64.70% loans Proportion of loans secured on fully- or 21.8% partially-let property WA seasoning (month) 45.6 WA Interest rate of pool 5.97% LTV Break-down Reference Portfolio The provisional pool as of the cut-off date 28 March 2002 forming the collateral for the notes consisted of 39,084 mortgage loans with a total outstanding balance of approximately EUR1.5billion. Property Market Value Original LT(A)V 95.4%* Beleihungswert Original LTV 85.9% Current LTV 82.8% Second Ranking loan Part Nachrang The mortgages included in the pool were originated through one of the bank s 789 branches in Germany. The first contact generally occurs directly through a branch but may also be initiated through one of several intermediaries such as building societies, mortgage banks, brokers, and real estate agents with which the bank has existing arrangements All loans are second ranking claims with an original LTLV of 60%. The maximum total LTLV including all prior ranking claims is 118%. Fitch analysed, on a loan-by-loan basis, the actual security position for the Start LTV 50.8% Internal Prior Charge 30.21% 3rd Party Prior lien 20.6% First Ranking loan Claim Vorrang * based on Appraised Value. All other loan-to-value figures are based on indexed Market Value. The concentration in the Neuen Länder (East Germany) is comparable to previous reference pools in 2

3 Germany. Fitch s methodology penalises loans secured on properties in Eastern Germany relative to other regions to reflect the limited history for this region as well as the development of the house price market during the 1990s. Key Information Issuer:, an Irish SPV Arranger: Commerzbank AG Certificate of Indebtedness issuer: Kreditanstalt für Wiederaufbau ( KfW ) Trustee: PwC Deutsche Revision AG Originator: Commerzbank AG Servicer: Commerzbank AG Pool Cut-Off Date: March Payments to Noteholders: quarterly in arrears on the 28 th day of January, April, July and October. Scheduled Maturity of the Notes: December 2033 Legal Maturity of the Notes: December 2035 Credit Issues Fitch analysed the reference portfolio for Provide Residence 2002 by subjecting the mortgage loans to stresses resulting from its assessment of historical home price movements and mortgage defaults in Germany (see Research German Mortgage Default Model ). This study shows that a borrower s LTV, which reflects the size of their downpayment and thus willingness to pay, and an affordability measure, such as debt-to-income (DTI), which indicates a borrower s ability to pay, are the key determinants of default probability in Germany. The following are particular areas of focus of Fitch s analysis of the credit quality of the collateral that forms the security for Provide Residence Default Probability Underwriting and Servicing Quality: Following a visit to Commerzbank s offices, Fitch considers the originator to be a good underwriter and servicer of German residential mortgage loans (a summary of the agency s review of Commerzbank can be found on page 6, Origination and Servicing ). Affordability Measures: Information on the reference pool with regard to affordability measures was not available on a loan-by-loan basis. During the origination process, however, Commerzbank puts much emphasis on a borrower s ability to pay, and maintains strict guidelines in this regard. Therefore, Fitch assumed that borrowers generally have an average ability to pay, equivalent to class 3 in the default model (see appendix II). Repayment Type: 35.3% of the portfolio are interest only loans that are repaid at maturity and do not amortise over time. These loans are subject to balloon risk if the borrower has insufficient funds at maturity. Therefore, Fitch generally increases default probability for these loans. However 100% of the interest only loans are linked to either life insurance or savings contracts ( Bausparverträge ) that are pledged to Commerzbank. These repayment substitutes partly mitigate the balloon risk but are still subject to performance risk, which was taken into account in the analysis. Property occupancy: 21.80% of the reference pool is secured by fully- or partially-let properties (investment properties). Germany has the lowest owner-occupancy rate in the EU. Fitch increased the base default probability for such properties by up to 25% in order to account for the increased default risk compared to mortgages secured by the primary residence. Loss Severity Market Value Decline: The primary determination for loss severity is the assumed market value decline ( MVD ). To estimate MVDs, Fitch examined home price movements in Germany on a regional basis from in the western Länder, and from in the eastern Länder (see Research German Residential Mortgage Default Model ). Based on the volatility and the current level of property prices compared to the long term-trend, the agency has determined MVD factors for five regions and seven cities in Germany. The weighted average MVD for this portfolio is 36.51% in a AAA Scenario. Recovery Value: The recovery value in synthetic RMBS transactions is determined by the definition of realised losses in conjunction with the allocation schedule of recovery proceeds over the various priorranking items (see Realised Losses below). 3

4 The basic recovery value is determined as the indexed property value reduced by the MVD factor and the principal amount of prior-ranking loan claims and third-party prior liens. Depending on the definition of realised losses and the allocation schedule of foreclosure proceeds the basic recovery value can be further reduced by foreclosure costs and accrued interest on prior-ranking loan parts and liens as well as the accrued interest on the reference claim. For this specific transaction, the definition of realised losses to be passed on to the credit default swap counterparties and the noteholders includes principal losses only. Hence this excludes foreclosure costs, accrued interest on the reference loan claim as well as prior-ranking loan claims. When calculating the recovery values and expected loss for each loan claim, only principal losses were taken into account. Loan-to-Value of prior charges: The loss severity is sensitive, inter alia, to both the total combined loan to market value ( LTV, including prior charges) as well as the relative security position expressed by the start LTV of the securitised claim. A high start LTV will mean that loss severity for the securitised portion will be increased relative to a loan of similar LTV with no prior liens. The weighted average start LTV for the current portfolio is 50.81%. This needs to be taken into account when comparing the credit enhancement with previous German portfolios. Financial Structure Credit Enhancement Credit enhancement for each class of notes is provided by subordination. Credit enhancement for the class A+ notes will be provided by subordination, which totals 16% and consists of the class A (3%), B (4%), C (3.25%), D (2.3%) and E notes (1.4%) and the junior CDS (2.1) The ratings of the notes are dependent on the credit quality of KfW, which Fitch has reviewed and found consistent with the ratings assigned to the notes (including the AAA notes). Should the credit quality of KfW deteriorate, the ratings of the notes would be subject to re-evaluation. Interest Payments Noteholders will receive quarterly interest payments in arrears based on three-month EURIBOR plus the applicable margin. Payments will be made on the 28 th day of January, April, July, and October. Principal Payments on the Notes The amortisation of the CDSs and the notes is linked to the amortisation of the notional amount of the reference portfolio. To avoid any doubt, there will be no physical cash transfers between KfW and the CDS counter-parties in respect of principal. Principal amounts will be allocated sequentially first to reduce the notional amount of the senior CDS and the A+ (allocation between senior CDS and A+ notes will be pro rata), then the class A, B, C, D and E notes, and finally to reduce the notional amount of the junior CDS. The notes are scheduled to be repaid in 2033, excluding principal on those notes corresponding to principal on overdue reference claims exceeding the remaining amount of the junior CDS, which will remain outstanding. The issuer shall redeem the notes prior to their legal maturity upon KfW exercising its prepayment option (in the event of adverse tax changes or regulatory changes) under the Certificates or as a result of the termination of all bank swaps. The bank swap can be terminated if either of the following occurs: Adverse regulatory changes Once the outstanding principal balance of the reference mortgage portfolios has been reduced to less than 10% of the initial balance at closing After the payment date, falling in 2009 Termination of the banks swaps occurs either due to: Non payment by the bank of amounts due under the bank swap Bankruptcy of the relevant bank Should the issuer fail to pay principal or interest within 30 business days, the noteholders have the right to request early redemption of the notes. Unless otherwise redeemed, the notes will be repaid on their legal final maturity date in

5 Realised Loss Allocation Realised losses to be passed on to the noteholders and the swap counterparties are determined based on the definition of realised losses in conjunction with the allocation schedule of recoveries, as set out below. 1. to principal on prior-ranking loan claims 2. to principal on the securitised loan balance Realised losses are defined as the remaining unpaid amounts of principal on the securitised loan balance. On each Payment Date, an amount equal to the realised losses on the mortgage pool will be passed to the noteholders and/or claimed under the junior/senior CDS agreement. In the event that losses occur, these will be allocated in reverse sequential order first to reduce the outstanding amount of the junior CDS, and then to reduce the outstanding principal amount of the class D to A notes. The senior CDS and the respective A+ notes share any losses allocated pro rata. The trustee verifies all realised losses annually, quarterly once they exceed EUR31,000,000. Credit Default Swaps The senior and junior CDS agreements will be entered into by KfW on the closing date, under which it buys credit protection from the junior and senior swap counterparties to hedge its exposure under the CDS with Commerzbank. The latter pays a quarterly fee to KfW and KfW will pay quarterly premiums to the senior and junior swap counterparties. In return, losses will be allocated to the CDSs according to the loss allocation (see Realised Loss Allocation above). Legal Structure The notes are EUR-denominated and issued by Provide Residence 2002, a bankruptcy-remote, special purpose vehicle based in Dublin, Ireland. The class A+ to E notes will be secured by credit-linked certificates of indebtedness ( Schuldscheine ) issued by KfW and purchased by the issuer on the closing date. These certificates will be executed in the form required by 780 of the German Civil Code ( abstraktes Schuldversprechen ) and will therefore be evidence of an abstract payment undertaking pursuant to 780. The amount payable under the certificates of indebtedness will be linked to the notes and ultimately to the performance of the reference pool. On the closing date, the issuer will pledge to the trustee all its present and future claims and rights under the certificates of indebtedness as well as all its future claims under the other transaction documents ( the senior pledges ). In addition, the issuer will, on the closing date, grant a second, junior pledge to the noteholders on all its present and future rights and claims under the certificates. The second pledge may not be exercised as long as the senior pledges in respect of the certificates exist. Commerzbank may transfer any reference claim to another bank or thirdparty, provided that Commerzbank remains responsible for the determination and allocation of losses and in the event of a transfer to a third-party, subject to the confirmation by the trustee. The trustee adopts some vital duties on behalf of the noteholders and the senior/junior swap counterparty. These duties of the trustee include, inter alia, to: Verify the determination and allocation of all realised losses once a year or quarterly if the notional amount of the junior CDS has been reduced to zero including the relevant loan s eligibility and the servicing standards applied; Verify all reports and documents supplied to it by the Commerzbank including pool performance reports; Appoint third-party experts when required; Origination and Servicing Fitch has reviewed Commerzbank s origination and servicing guidelines, and performed an on-site review with managers of the relevant departments. Commerzbank originates mortgage loans either via its branch network or through intermediary groups. The bulk of business (80%) is originated through existing branch customers or direct enquiries from advertising. The market segment that Commerzbank targets are generally more high net worth individuals. The origination process is a two-step process with first a review by the account manager and then a credit analyst. Commerzbank uses underwriting software which uses various factors to classify risk as black, grey or white. Black risks are automatically rejected; white risk is good risk ; grey risk is critical risk requiring closer scrutiny and additional analysis. The account manager performs a quick check on the applicant s ability to pay and the applicant s personal net worth. A credit bureau report is also obtained from SCHUFA, a German credit bureau, to verify the historical credit information of the borrower. The borrower s monthly cash flow situation is also worked 5

6 through to ensure they have a minimum available income amount to service the debt. Commerzbank requires a minimum amount of available income per month (a required lump sum) which varies according to the number of people living in the household. The usual standard requirement is EUR650 for a single person per month, EUR850 for a couple and EUR200 for each additional person. The black, grey or white classification results from this analysis. Account managers are based in Commerzbank s 789 branches; credit analysts are based in larger regional branches. The signatures of two people, usually the account manager and credit analyst are needed to approve the loan. The following documents are amongst those required before a decision can be made on granting a loan: Personal information about the borrower, such as marital status, employment, etc. Documents confirming creditworthiness of the borrower, including a salary statement, income tax filing, and a statement of assets and liabilities. A detailed description of the property (valuation report, construction plans). The land registry excerpt. For loans up to EUR300,000 the responsible customer service manager or credit officer can value ( Kleindarlehensgrenze ) the underlying property. All other properties are valued by qualified surveyors from the internal appraisal department. Commerzbank requires an on site visit for each property. Any property built prior to 1950 has to be evaluated by an external appraiser. The valuation assigns a lending value which is typically at least at a 10% discount to the property s market value (and more for older properties). Once a loan is granted, Commerzbank s loan administration team will perform servicing duties. Commerzbank will service the loans in the reference portfolio according to the same procedures and guidelines it services the rest of its portfolio. In the event of a conflict of interest between Commerzbank and the noteholders, Commerzbank will not place the noteholders in a less favourable position than itself. Servicing and Workout Via a computer-based payment reminder system, the administration department can identify immediately those loans on which a payment has been missed. After 17 days, an initial automatic reminder is sent out, and if there is no response, a second is dispatched after another 17 days (and every 17 days thereafter until two payments are overdue). The account manager must also contact the delinquent borrower. Once a loan is two instalments overdue it is transferred to the intensive care department that seeks to make an arrangement with the borrower. Ultimately if no arrangement can be reached, the file passes to the foreclosure department. Here a methodical procedure that involves the following steps is undertaken: 1. New internal valuation of the property is carried out. The co-operation of the borrower is sought to achieve an open sale of the property. 2. If the borrower does not co-operate the bank will proceed with the foreclosure process (this can take up to two years). A valuation by an expert working for the court will have to be sought. According to the new German law governing foreclosure proceedings (Gesetz ueber Zwangsversteigerung und Zwangsverwaltung) a minimum value of 50% of the expert s valuation has to be reached through the bidding. Subject to approval from Fitch, another bank or thirdparty servicer may substitute Commerzbank, in its role as the loan servicer, as long as the standards of servicing and the determination of losses remain unchanged. Surveillance Fitch will monitor the transaction on a regular basis and as warranted by events. Its structured finance surveillance team ensures that the assigned ratings remain, in the agency s view, an appropriate reflection of the issued notes' credit risk. Details of the transaction's performance are available to subscribers at Please call the Fitch analysts mentioned on the first page of this report for any queries regarding the initial analysis or the ongoing surveillance. 6

7 Appendix I: Rating Methodology To determine appropriate levels of credit enhancement, Fitch analyses the collateral for German residential transactions using a loan-by-loan mortgage default model (see Research German Residential Mortgage Default Model 2001, dated 7 September 2001, available on The model subjects the mortgage loans to stresses resulting from the agency s assessments of historical home price movements and mortgage defaults in Germany. Fitch s study showed that the borrower s LTV, reflecting the size of down payment and willingness to pay, and the borrower s debt-to-income ratio (DTI) or income multiple, reflecting ability-to-pay, are the key determinants of default probability in Germany. Default Probability Generally, the two key determinants of default probability are the borrower s willingness and ability to make the mortgage payments. Willingness is usually measured by the LTV. Fitch s model assumes higher default probabilities for high LTVs, the main reason being that in a severe negative equity situation, borrowers in financial distress but with equity in their homes (low LTV loans) have an incentive to sell and maintain/protect their equity, eliminating the need for the lender to repossess the property. However Germany is characteristically a high-ltv market. Fitch accounts for this and places a greater emphasis on affordability when determining default probability. The ability to pay is usually measured by the borrower s net income in relation to mortgage repayments. The available historical data shows lower levels of default by German borrowers compared to neighbouring countries. Base default probabilities are determined by using a matrix that considers each loan s affordability factor and LTV. The matrix classifies affordability into five classes, the lowest of which (Class 1), encompasses loans with Debt-to-Income ratios (DTI) of less than 20% and the highest of which (Class 5) encompasses all loans with DTIs exceeding 50%. A loan classified as affordability class 3, for example, would be allocated a base default probability of 6-31%, depending on LTV. Adjustments Fitch adjusts the base default rates on a loan-by-loan basis to account for individual loan characteristics of the collateral across all rating levels. Repayment type: Interest Only Fitch generally increases the default assumptions for interest-only mortgages, whereby the mortgage is secured solely by the property value and principal is repaid by the borrower in one lump sum upon loan maturity, to take into account the potential payment shock to the borrower and the strong reliance on the borrower s equity in the property. Second Home and Investment Properties: Fitch believes that a borrower is more likely to default on a loan secured on investment properties or second home than one secured on a primary residence. Therefore Fitch has increased the default probability by 15% - 25% for these loans. Borrower Profile: Fitch increases default probability on loans to self-employed borrowers by 30% to account for the increased income volatility. Arrears Status: When rating portfolios combining current and arrears mortgages, Fitch increases base default rates for mortgages in arrears by up to 90 days by 25%-75%, and mortgages over 91 days in arrears (non-performing status) by 100%. However none of the past portfolios included any loans in arrears for more than 30 days. Underwriting Quality: Fitch s analysis takes into account the underwriting and servicing standards of the originator. Based on the outcome of the review process default rates may be decreased by up to 25% or increased by 0%-200%. However, German originators are generally very conservative with regards to mortgage lending, and origination and servicing procedures do not vary greatly between originators. Seasoning: Fitch believes that mortgage loans which have been fully performing for more than five years are less susceptibale to default than less seasoned loans, given that the borrower will have increased their equity share and the value of the property will have gone up. Therefore, Fitch will reduce default probability on a case by case basis by up to 30% for loans older than five years. 7

8 Loss Severity To estimate loss severity on the mortgage loans in Germany, Fitch examined home price movements for 60 cities in the country. The cities were grouped into five regions, excluding the largest cities like Munich and Hamburg. Given the lack of data for rural areas on a more aggregate basis, Fitch could not take into account differences between the cities in a region and the rural areas in the same region. Worst-case MVDs were estimated based on volatility and distance to the long-term trend. As in its other European mortgage default models, Fitch increased MVDs for properties worth more than EUR 400,000 by 10% 25%. Higher value properties tend to have larger MVDs owing to the smaller marketplace for these properties and less precise pricing information for larger properties (owing to the less active market). When calculating recovery value, Fitch s model reduces each property valuation by the MVD, repossession costs, prior liens and the cost to the servicer of carrying the loan from delinquency through to default. On the basis of worst-case information gathered from German mortgage lenders, Fitch assumes repossession costs represent 2% of the property value. To calculate carrying cost, Fitch assumes that the borrower does not pay interest for 24 months and that interest accrues during this period at the applicable mortgage rate. However, repossession costs and the cost of carry can be excluded from losses in synthetic transactions. Prior charges include higher ranking loans held by the same originator or a third-party as well as higher ranking loan parts, especially Pfandbrief Deckungsstock eligible loan parts. The highest capital relief is achievable by securitising only the loan parts in excess of 60% of the lending value, which are not eligible for Pfandbrief Deckungsstock and carry a 50% risk weighting. Property Market Value Property Lending Value (85%- 90% of the Market Value) only for Mortgage Banks Second Ranking loan part ( Nachrang ) (100% risk weighting) Total Loan Balance 60% Loan to Lending Value (LtLV) Eligible for Mortgage Pfandbriefe (50% risk weighting) Prior Lien Positions 8

9 Copyright 2002 by Fitch, Inc. and Fitch Ratings, Ltd. and its subsidiaries. One State Street Plaza, NY, NY Telephone: , (212) Fax: (212) Reproduction or retransmission in whole or in part is prohibited except by permission. All rights reserved. All of the information contained herein is based on information obtained from issuers, other obligors, underwriters, and other sources Fitch believes to be reliable. Fitch does not audit or verify the truth or accuracy of any such information. As a result, the information in this report is provided as is without any representation or warranty of any kind. A Fitch rating is an opinion as to the creditworthiness of a security. The rating does not address the risk of loss due to risks other than credit risk, unless such risk is specifically mentioned. Fitch is not engaged in the offer or sale of any security. A report providing a Fitch rating is neither a prospectus nor a substitute for the information assembled, verified, and presented to investors by the issuer and its agents in connection with the sale of the securities. Ratings may be changed, suspended, or withdrawn at any time for any reason at the sole discretion of Fitch. Fitch does not provide investment advice of any sort. Ratings are not a recommendation to buy, sell, or hold any security. Ratings do not comment on the adequacy of market price, the suitability of any security for a particular investor, or the tax-exempt nature or taxability of payments made in respect to any security. Fitch receives fees from issuers, insurers, guarantors, other obligors, and underwriters for rating securities. Such fees generally vary from US$1,000 to US$750,000 (or the applicable currency equivalent) per issue. In certain cases, Fitch will rate all or a number of issues issued by a particular issuer, or insured or guaranteed by a particular insurer or guarantor, for a single annual fee. Such fees are expected to vary from US$10,000 to US$1,500,000 (or the applicable currency equivalent). The assignment, publication, or dissemination of a rating by Fitch shall not constitute a consent by Fitch to use its name as an expert in connection with any registration statement filed under the United States securities laws, the Financial Services Act of 1986 of Great Britain, or the securities laws of any particular jurisdiction. Due to the relative efficiency of electronic publishing and distribution, Fitch research may be available to electronic subscribers up to three days earlier than to print subscribers. 9