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Secure with Securitisation: Global Volumes Expected to Rise in 2025

-Dayita Kanodia (finserv@vinodkothari.com)

Despite global macroeconomic challenges, including persistent inflation, securitization volumes and ratings across most structured finance asset classes demonstrated remarkable stability in FY 2024. Strong housing markets bolstered credit performance in sectors like U.S. and Australian RMBS, while European housing markets faced concerns of overvaluation. 

Overall, the performance of the securitisation market in FY 2024 was considered to be stable with a few exceptions of leveraged lending and collateralized loan obligations (CLOs) which remained in focus for numerous reasons, including their elevated exposures to lower-rated obligors.1

This article delves into the securitization trends observed in FY 2025, analyzing the market’s performance and offering insights into future projections.

Global Securitisation Volumes for FY 2025

US 

As of December 2024, the total US Structured Finance issuance reached USD 770 Billion. In this, the total RMBS issuance accounted for USD 137.9 Billion (17.9% of the total structured finance issuance). It may be noted that total RMBS issuance for FY 2023 amounted to USD 78 Billion, therefore leading to an increase of roughly 76% in the current fiscal year. Securitisation of Credit Card receivables accounted for about USD 20.6 Billion while auto loans accounted for USD 126.4 Billion.2

As per S&P Global, the total credit card ABS issuance will be about $33 billion in 2025 thus leading to a 60% increase from the previous year. It also estimates the total RMBS issuance to reach USD 160 Billion supported by home price appreciation and low unemployment rates. 

The below chart shows structured finance issuances by sub-sector:

Traditionally, US data has excluded agency-backed transactions (the data above, therefore, would mostly be non-qualifying residential mortgage loans). SIFMA data shows that agency and non-agency RMBS issuance added to USD 1.592 trillion, registering an increase of 21%. This includes an increase of 119% in non-agency RMBS, and about 19% in agency-RMBS.

Yet another segment which is typically boosted by the benign credit conditions is CMBS. US CMBS volumes touched USD 103 billion [S&P data]. This is over 2.5 X of the volume seen last year.

European Market

European securitisation issuance in 2024 reached USD 142 billion, reflecting an over 50% increase compared to 2023.While fewer outstanding transactions in the European securitisation market are anticipated to hit their call dates in 2025, typically a factor that negatively impacts volumes; improvements in underlying credit originations offer a positive outlook3.

A highlight of 2024 was the record-setting bank-originated securitisations, which soared to a 12-year high of over USD 36 billion. Additionally, sustainable-labelled securitisation rebounded strongly, with issuances exceeding USD 5 billion during the year. RMBS volumes in Europe rose by approximately 60% to USD 46 billion, a trend likely to persist into 2025.

The below chart shows the RMBS and ABS issuance over last 3 years in the European market:

China 

In China, new securitization issuances grew by 4.8% year-on-year to USD 200 billion during 1Q-3Q 2024. Issuances of consumer loan ABS and account receivables ABS saw noticeable growth and MSE loan ABS issuances surged by 76%. However, the issuance of certain major asset classes, such as auto loan ABS declined significantly (Auto loan ABS issuance fell 39% in 1Q-3Q 2024 to USD 11.83 billion. The number of transactions issued during the period dropped to 22 from 29 a year earlier).4

Consultation on Securitisation

A highpoint  of the EU securitisation market in 2024 is the consultation by the  European Commission to mend the regulatory framework for securitisation. This exercise was prompted by several positive noises about securitisation at a policy-makers’ level. Enrico Letta, former Italian Prime Minister, in his report to the EU, made a strong case for securitisation. He said: “Securitization acts as a unique link between credit and capital markets. In this sense, the securitization market offers significant potential. Increasing its utilization brings two key benefits: i) broadening and diversifying the pool of assets available for investment, and ii) unlocking banks’ balance sheet capacity to facilitate additional financing. Moreover, the adoption of green securitization, whether through securitizing green assets or directing securitization proceeds towards green financing, holds promise as a significant contributor to the transition towards sustainability. Therefore, we advocate for reforms in the European securitization framework to enhance its accessibility and effectiveness”5 In addition, comments by Noyer and those by Mario Draghi favoured changes in securitisation framework. Thus, in October, 2024, the Eurpean Commission began a targeted consultation on several aspects of securitisation market. The responses from the consultation are currently available on the Commission’s website

Surge in CLO market

One of the notable developments in 2024 was the surge in CLO volumes. US CDO/CLO issuance, as per SIFMA statistics, recorded an issuance volume of USD 85 billion, which is 195% higher than the issuance last year. European CLO volume registered a volume of Euro 46 billion, substantially higher than last year. One report, citing a BofA research, states that the global outstanding CLO volume reached nearly USD 1.2 trillion. 

The growth in the CLO market is a direct result of the activity in the leveraged loan market, as the feedstock of CLOs primarily is leveraged loans. Leveraged loans, a term that is rather understood than defined, is mostly low-rated loans to entities that are already carrying significant leverage. The US leveraged loan market adds to upwards of USD 1.2 trillion, and that in Europe stood at about Euro 280 billion. Most of these leveraged loans tend to “syndicated” or downsold in pieces to various participating banks – which may number from a dozen to even 200, and hence, reflecting the extent of lender participation, this market is called “broadly syndicated loan” or BSL market.

While private credit financiers are increasingly making inroads into the space, a lot of capital in the leveraged loan market comes from CLOs. 

Another interesting development in the US CLO market has been the growth of CLO ETFs. A report by S&P says that CLO ETFs’ AUM rose from USD 120 million in 2020 to USD 19 billion in Nov., 2024.

Regulatory updates

UK enacted the Securitisation Regulations, 2024, which replaced the earlier 2017 Regulations. Pursuant to the Regulations, the Financial Conduct Authority has framed the set of rules called Securitisation Sourcebook. The rules lay particular emphasis on the Simple, transparent and standardised (STS criteria) of securitisation transactions, and by way of amendments made later in the year, bar the domiciling of SPVs in certain high risk jurisdictions.

Growth in synthetic securitisation

Synthetic securitisation, also sometimes known as synthetic risk transfer or significant risk transfer (SRT) transactions, were mostly limited to Europe and SE Asia jurisdictions, due to lack of clarity on regulatory capital treatment in the USA. In Sept., 2023, the Federal Reserve board clarified that capital relief will be applicable in case of synthetic transactions. Since the clarification, US share in global synthetic securitisations grew to over 30%, from a small fraction earlier. The IMF Global Financial Stability Report of October, 2024 states that globally, more than $1.1 trillion in assets have been synthetically securitized since 2016, of which almost two-thirds were in Europe.

The said IMF report highlights several risks of SRT transactions. First of all, it states, basis anecdotal evidence, that banks are providing funding to credit funds for buying tranches of SRT deals of other banks, thereby implying that the risks are eventually within the banking system. It also states that SRTs may “mask banks’ degree of resilience because they may increase a bank’s regulatory capital ratio while its overall capital level remains unchanged.” Furthermore, overreliance on SRTs exposes banks to business challenges should liquidity from the SRT market dry up. Financial innovation may lead to securitization of riskier asset pools, challenging banks with less sophisticated tools for risk management, because some more complex products make the identity of the ultimate risk holder less clear. Finally, although lower capital charges at a bank level are reasonable, given the risk transfer, cross-sector regulatory arbitrage may reduce capital buffers in the broad financial system while overall risks remain largely unchanged. 

Sustainable-labelled Securitisation

The European market saw an issuance exceeding USD 5 Billion during 2024 with first time issuances in solar ABS sectors. 

In the U.S., government-sponsored enterprises are purchasing mortgage pools targeting low-carbon buildings and refinancing these assets in the mortgage-backed securities market to finance energy and water efficiency programmes6. For instance, in September 2024, Fannie Mae a GSE came up with a single family green bond framework. Under this framework, loans which conform to the eligibility requirements are acquired from lenders and are securitised into Fannie Mae MBS which are either delivered to the lenders or sold to investors. Here, only projects achieving certain environmental performance standards such as Solar Loans and water efficiency loans are eligible7

Indian Securitisation Market8 

Securitisation volumes surged about 27% on-year to Rs 1.78 lakh crore in the first nine months of FY 24-25, supported by large issuances from private sector banks. In the third quarter alone, issuances touched Rs 63,000 crore with private sector banks contributing to 28% of this (HDFC bank alone securitised new car loans by issuing PTCs valued at just over Rs 12,700 crore). However, originations by NBFCs were only up by 5%. The market also saw 15 first time NBFC issuers, bringing the total number of originators to 152, compared with 136 in the last financial year. 

Among asset classes, vehicle loans (including commercial vehicles and two-wheelers) accounted for 48% of securitisation volume (vs 40% in the corresponding period last fiscal).

Mortgage-backed loans accounted for about 23% of securitisation volume (vs 20% in the corresponding period last fiscal). 

Overall, the Indian Securitisation Market volume is expected to reach Rs 2.4 trillion by the end of FY2025. 

On the regulatory front, SEBI, in its board meeting dated December 18, 2024, approved amendments to the framework for the issuance and listing of Securitised Debt Instruments (SDIs). These amendments aim to expand the SDI market and align the regulations with the current securitisation norms prescribed for RBI-regulated entities.

This growth trajectory is expected to persist into FY26, fueled by strong securitization volumes and the expanding involvement of private sector banks. With evolving market dynamics and growing investor confidence, the securitization market is poised for sustained momentum for years to come.

Related articles: 

  1. India securitisation volumes 2024: Has co-lending taken the sheen?
  2. Indian securitisation enters a new phase: Banks originate with a bang
  3. Securitisation: Indian market grows amidst global volume contraction
  1.  https://www.spglobal.com/_assets/documents/ratings/research/101591938.pdf
    ↩︎
  2.  https://www.spglobal.com/_assets/documents/ratings/research/101610419.pdf
    ↩︎
  3.  https://www.spglobal.com/ratings/en/research/pdf-articles/easset_upload_file78691_3234527_e.pdf
    ↩︎
  4.  https://www.spglobal.com/_assets/documents/ratings/research/101607929.pdf
    ↩︎
  5.  https://www.consilium.europa.eu/media/ny3j24sm/much-more-than-a-market-report-by-enrico-letta.pdf
    ↩︎
  6.  https://www.spglobal.com/_assets/documents/ratings/research/101604403.pdf ↩︎
  7.  https://capitalmarkets.fanniemae.com/media/20626/display
    ↩︎
  8. Source – https://www.crisilratings.com/en/home/newsroom/press-releases/2025/01/securitisation-volume-up-27percent-in-nine-months-of-this-fiscal.html
    ↩︎

Full Day Workshop on Securitisation,Transfer of Loans and Co-lending

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However, don’t worry we are announcing a repeat workshop on 21st May, 2025

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Our resources on new Securitisation and Transfer of Loan Directions

Full Day Workshop on Securitisation,Transfer of Loans and Co-lending

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https://forms.gle/kbjwwAmayAWKJwZr5

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Our resources on new Securitisation and Transfer of Loan Directions

Simple, Transparent and Comparable (STC) securitisation: Discrepancy in risk weights needing urgent remedy

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Our resources on Securitisation:

  1. What is securitisation?
  2. Basel III requirements for Simple Transparent and Comparable (STC) Securitisation
  3. IOSCO Paper on Simple, Transparent and Comparable (STC) securitization
  4. Time value of money, NPVs, IRRs

Indian securitisation enters a new phase: Banks originate with a bang

Abhirup Ghosh | abhirup@vinodkothari.com

The Indian securitisation market has been without banks as originators for nearly 17 years, until HDFC Bank[1] launched a landmark transaction that may signal their potential return. Prior to the Global Financial Crisis, which raised significant questions about the viability of securitization as a financial product, banks like ICICI Bank were actively involved in the market, with ICICI’s last reported transaction occurring in 2007[2].

It is notable that erstwhile HDFC Limited, prior to its merger into the Bank, was the largest single originator of home loan securitisations; however, the present transaction is not home loans.

After the GFC, banks shifted from being originators to becoming investors in securitised assets. To meet the priority sector lending targets, banks started investing heavily in the securitisation market, be it in pass-through certificates or through acquisition of loan pools. This was a stark contrast to the situation elsewhere in the world, where the issuances are primarily made by banks.

Read more

Representation for Regulatory Amendments to Promote Securitisation in India 

Team Finserv | finserv@vinodkothari.com

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Vikas Path: The Securitised Path to Financial Inclusion

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Key Takeaways – 12th Securitisation Summit, 2024

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Access our Publication launched during the 12th Securitisation Summit here.

Agenda – 12th Securitisation Summit | May 15, 2024

Summit home page can be viewed here: https://vinodkothari.com/secsummit/

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Lend, Recover, Replenish: A guide to revolving lines of credit

“Chivalry is like a line of credit. You can get plenty of it when you do not need it.”

— Nellie L. McClung

Dayita Kanodia | Finserv@vinodkothari.com

In the realm of financial management, having access to a flexible and readily available source of funds can be a game-changer for individuals and businesses alike. One such financial tool that offers this flexibility is a revolving line of credit. Often misunderstood or overlooked, revolving lines of credit are versatile financial instruments that can provide quick access to funds when needed.

A revolving line of credit is a type of loan arrangement that provides borrowers with access to a predetermined amount of funds, which they can borrow, repay, and borrow again as needed. Unlike traditional term loans, where you receive a lump sum upfront and repay it over a set period with fixed payments, a revolving line of credit offers ongoing access to funds that can be drawn upon at any time, up to the credit limit.

Revolving line of credits has been defined as a committed loan facility allowing a borrower to borrow (up to a limit), repay, and re-borrow loans.These are also known as revolving credit facilities, replenshing loans, revolving loans,  or just revolver. 

How Does it Work?

When one opens a revolving line of credit, there is an approval for a certain credit limit based on factors such as creditworthiness, income, and other financial obligations. Once approved, funds can be accessed from the credit line as needed, either by writing checks, using a debit card, making online transfers, or withdrawing cash, depending on the terms of the agreement.

The line of credit is drawn down as disbursements occur. However, the limit is reinstated to the extent repayment is made by the borrower. Obviously, the borrower is free to repay the whole or a part of the limit anytime, and there is no question of any prepayment charge. 

It is not as though a revolving line of credit will continue to revolve all the time – the lender may set a renewal date, and if the facility is not renewed, the lender may convert it into either an instalment credit, or one payable in one or more tranches at a defined time. During the period the facility remains revolving, the borrower services interest.

It is also important to note that during such time, and for such amount, the facility is not used not used fully, the lender still keeps a commitment to lend alive, which has both liquidity burden as well as regulatory capital charge for the lender. Therefore, it is perfectly okay for a lender to provide for a commitment charge for the unutilised facility amount. 

Features of Revolving Lines of Credit

  • Revolving Nature: Unlike traditional term loans, revolving lines of credit allow borrowers to repeatedly borrow and repay funds without the need to reapply for a new loan each time.
  • Interest on Utilized Amount: Interest is typically charged only on the amount of credit actually used, rather than on the entire credit limit. This can result in lower interest costs for borrowers who do not fully utilize their credit line.
  • Variable Interest Rates: Interest rates on revolving lines of credit may be variable, meaning they can fluctuate over time based on market conditions. This can be advantageous if rates decrease but may pose risks if rates rise.
  • No Fixed Repayment Schedule: Unlike term loans with fixed monthly payments, revolving lines of credit typically have no fixed repayment schedule. Borrowers can repay the borrowed amount on their own timeline, as long as they make at least the minimum required payments.
  • Credit Renewal: As long as the borrower meets the terms and conditions of the credit agreement, revolving lines of credit can be renewed indefinitely, providing ongoing access to funds.

Lines of credit and its types

The US Federal Reserve has distinguished between revolving and non-revolving lines of credit. It says, 

“Revolving credit plans may be unsecured or secured by collateral and allow a consumer to borrow up to a prearranged limit and repay the debt in one or more installments. Credit card loans comprise most of revolving consumer credit measured in the G.19, but other types, such as prearranged overdraft plans, are also included. Nonrevolving credit is closed-end credit extended to consumers that is repaid on a prearranged repayment schedule and may be secured or unsecured. To borrow additional funds, the consumer must enter into an additional contract with the lender.”

Credit can be classified as:

Revolving Credit: A fixed line of credit is determined from where draw down take place. The line of credit then gets reinstated on repayment by the borrower.

Non-Revolving Credit: They provide borrowers with access to funds up to a predetermined credit limit which does not get reinstated on repayments being made. To borrow additional funds, a new contract has to be entered into.

Installment Credit: Installment credit involves borrowing a specific amount of money upfront and repaying it over a set period in equal installments, typically including both principal and interest.

Non-installment Credit: In case of non-installment credit, repayment does not happen in equal installments over a period of time but there is generally a bullet repayment made by the borrower.

Types of revolving lines of credit

Revolving lines of credit come in various types, each tailored to meet specific needs and circumstances:

Personal Revolving Line of Credit: 

This type of credit is designed for individual consumers and can be used for various personal expenses, such as home renovations, unexpected medical bills, or debt consolidation. Personal revolving lines of credit offer flexibility in borrowing and repayment, allowing individuals to access funds as needed.

Working Capital Revolving Line of Credit: 

Businesses often use this type of credit to manage cash flow, finance day-to-day operations, purchase inventory, or cover short-term expenses. Working capital revolving lines of credit provide flexibility for businesses to access funds when needed and repay them as cash flow allows, helping to smooth out fluctuations in revenue and expenses.

Secured and Unsecured Revolving Line of Credit: 

Secured lines of credit require collateral, such as real estate, inventory, or equipment, to secure the credit line. Because the lender has the security of collateral, secured lines of credit typically offer lower interest rates and higher credit limits compared to unsecured lines of credit.

Unsecured lines of credit do not require collateral. Instead, the creditworthiness of the borrower determines the credit limit and terms of the line of credit. Interest rates for unsecured lines of credit may be higher, and credit limits lower, compared to secured lines, but they offer the advantage of not requiring collateral.

Home Equity Line of Credit (HELOC): 

A HELOC is a revolving line of credit that is secured by the equity in a borrower’s home. Homeowners can borrow against the equity in their home up to a certain limit, using the home as collateral. HELOCs often have lower interest rates compared to other forms of credit and may offer tax benefits, but they carry the risk of foreclosure if payments are not made.

Revolving Credit Cards: 

Credit cards are a common form of revolving line of credit. They allow cardholders to make purchases up to a certain credit limit, repay the balance, and then borrow again up to the credit limit. Revolving credit cards typically have variable interest rates and may offer rewards or cashback incentives.

Maintenance of Regulatory Capital

According to para 5.9.3 of the Basel III Master Circular, revolving lines of credit can be considered as retail claims for regulatory capital purposes and included in a regulatory retail portfolio if they meet certain conditions. :

However, it is important to understand that a revolving facitliy has a drawn amount (and therefore, on-balance sheet exposure), and the undrawn amount (which is off balance sheet exposure). 

Para 5.15.2 (iv) of the Basel III Circular states that, 

“Where the non-market related off-balance sheet item is an undrawn or partially undrawn fund-based facility, the amount of undrawn commitment to be included in calculating the off-balance sheet non-market related credit exposures is the maximum unused portion of the commitment that could be drawn during the remaining period to maturity. Any drawn portion of a commitment forms a part of bank’s on-balance sheet credit exposure.”

Accordingly, say there is a credit facility for Rs.100 lakh (which is not unconditionally cancellable) where the drawn portion is Rs. 60 lakh, the undrawn portion of Rs. 40 lakh will attract a Credit Conversion Factor of 20 per cent. 

The credit equivalent amount of Rs. 8 lakh (20% of Rs.40 lakh) will be assigned the appropriate risk weight as applicable to the counterparty/rating to arrive at the risk weighted asset for the undrawn portion. The drawn portion (Rs. 60 lakh) which forms a part of the bank’s on-balance sheet credit exposure will attract a risk weight as applicable to the counterparty/rating.

Liquidity Risk 

According to para 131 of the Basel III: The Liquidity Coverage Ratio and liquidity risk monitoring

tools any contractual loan drawdowns from committed facilities and estimated drawdowns from revocable facilities within the 30-day period should be fully reflected as outflows. 

In case of committed credit facilities to retail and small business customers, banks have to assume a 5% drawdown of the undrawn portion whereas in case of non-financial corporates, drawdown has to be assumed for 10% of the undrawn amount.

Can revolving lines of credit be Transferred or Securitised ?

Transfer of Revolving Lines of Credit:

In case of a revolving line of credit, there is typically an undrawn amount. Accordingly, the transfer can only happen for the amount already drawn. However, in terms of the RBI Master Direction – Reserve Bank of India (Transfer of Loan Exposures) Directions, 2021 (‘TLE Directions’), the requirement of Minimum Holding Period (‘MHP’) needs to be fulfilled. This MHP requirement is of 3 months for loans having tenure of upto 2 years. Therefore, for loans having very short tenure, it may not be possible to fullfill the same. 

Accordingly, although there is no express prohibition from transferring the line of credit exposure, it may not be practical to do so. 

Securitisation of revolving lines of credit:

As per para 6(d) of the Master Direction – Reserve Bank of India (Securitisation of Standard Assets) Directions, 2021 (‘SSA Directions’) securitisation of revolving credit facilities is not permitted. Accordingly, revolving lines of credit cannot be securitised. 

Obtaining Default Loss Guarantee for Revolving Lines of Credit

Default Loss Guarantee(DLG) can only be obtained for digital loans. Since, revolving credit facilities (say, credit cards) may be offered through digital means it is important to discuss if DLG can be obtained for revolving lines of credit. The RBI FAQs (FAQ No.10) on Default Loss Guarantee (‘DLG FAQs) have prohibited REs from entering into DLG arrangements with respect to revolving lines of credit. 

For other non-digital revolving lines of credit provided, the bar on synthetic securitisation continues to apply and therefore, no default loss guarantee can be obtained. 

Conclusion

In a world where financial needs can arise unexpectedly, having access to a revolving line of credit can be invaluable. However, it’s essential for lenders to understand the regulatory requirements and implications associated with these credit facilities to ensure compliance and mitigate risks effectively.

Related Articles – 

Personal revolving lines of credit by NBFCs: nuances and issues

The Credit Card Business for NBFCs

FAQs on Default Loss Guarantee in Digital Lending