Fitch Rates Citigroup Mortgage Loan Trust 2015-A

NEW YORK--()--Fitch Ratings rates Citigroup Mortgage Loan Trust 2015-A (CMLT 2015-A) as follows:

--$209,359,000 class A-1 notes 'Asf'; Outlook Stable;

--$209,359,000 class A-1-IO notional notes 'Asf'; Outlook Stable;

--$209,359,000 class A exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-2 exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-2-IO notional exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-3 exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-3-IO notional exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-4 exchangeable notes 'Asf'; Outlook Stable;

--$209,359,000 class A-4-IO notional exchangeable notes 'Asf'; Outlook Stable;

--$149,923,000 class Aa exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class Ab exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class Ac exchangeable notes 'Asf'; Outlook Stable;

--$149,923,000 class A-1a exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-1b exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-1c exchangeable notes 'Asf'; Outlook Stable;

--$149,923,000 class A-2a exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-2b exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-2c exchangeable notes 'Asf'; Outlook Stable;

--$149,923,000 class A-3a exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-3b exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-3c exchangeable notes 'Asf'; Outlook Stable;

--$149,923,000 class A-4a exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-4b exchangeable notes 'Asf'; Outlook Stable;

--$29,718,000 class A-4c exchangeable notes 'Asf'; Outlook Stable;

Fitch has withdrawn expected ratings on the class B1, B2 and B3 residential mortgage-backed securities to be issued by Citigroup Mortgage Loan Trust 2015-A, originally issued March 24, 2015. The ratings have been withdrawn because Fitch has no longer been requested to rate these notes.

The $22,436,000 class B-4 notes, the $20,059,966 class B-5 notes, the $297,173,966 notional class X-IO notes are also not rated by Fitch.

The notes are supported by 994 re-performing mortgage loans with a total balance of approximately $297.2 million as of the cutoff date. Distributions of principal and interest and loss allocations are based on a senior subordinate, shifting-interest structure.

The 'Asf' rating on class A-1 notes reflects the 29.55% subordination provided by the 6.00% class B-1, 4.85% class B-2, 4.40% class B-3, 7.55% class B-4, and 6.75% class B-5 notes.

Fitch's rating on the class A-1 notes reflects the credit attributes of the underlying collateral, the quality of the servicer, Fay Servicing LLC. rated RPS3 by Fitch, the representation (rep) and warranty framework, minimal due diligence findings, and senior subordinate, shifting interest structure.

KEY RATING DRIVERS

100% Clean Current Re-performing Loans: The collateral pool consists primarily of peak-vintage seasoned re-performing loans (RPLs) all of which have been current with their monthly payments for the past 36 months. Approximately 49% of the loans have received modifications.

Solid Rep Framework: Fitch views the representation, warranty, and enforcement mechanism (RW&E) construct for this transaction to be generally consistent with what the agency considers a full framework with the exception of very minor variances. Citigroup Global Markets Realty Corp. (CGMRC), a subsidiary of Citigroup ('A/F1'/Stable Outlook), is providing life of loan reps. While some reps have knowledge qualifiers, they are subject to a clawback provision. Fitch categorized the framework as a Tier 2 due to the small variances.

Limited Due Diligence Findings: Third-party due diligence was conducted on 100% of the pool by JCIII and Associates, Inc. (JCIII), which covered regulatory compliance, pay history, and servicing comments. Roughly 101 loans had grades of 'C' and five were graded 'D' for compliance due to missing documentation. Fitch applies longer timelines for RPL transactions, which addresses the 'C' grades, and reliance was placed on the reps for those graded 'D'. Meridian Asset Services (Meridian) performed the tax and title search as well as the custodial file review on 100% of the loans. All but 206 loans (out of 994 loans) have assignments and intervening assignments recorded. CGMRC will repurchase loans not recorded within a year from deal closing.

No Servicer P&I Advances: The servicer will not advance delinquent monthly payments of principal and interest (P&I) to the extent not collected from borrowers to the trust. Therefore, such P&I advances will not accrue as additional carry costs on loans that become delinquent and eventually liquidate. As a result, the loss severity (LS) calculated by Fitch is less than if the servicer was obligated to advance P&I through liquidation, as is standard for most prime jumbo transactions of newly originated loans.

Potential Interest Deferrals: To address the lack of an external P&I advance mechanism, principal otherwise distributable to the notes may be used to pay monthly interest. Principal is available to pay interest on notes. As a result, bonds may experience long periods of interest deferral that will generally not be repaid until such note becomes most senior outstanding.

Under Fitch's 'Criteria for Rating Caps and Limitations in Global Structured Finance Transactions' dated May 2014, the agency may assign ratings up to 'Asf' on notes that incur deferrals if such deferrals are permitted under the terms of the transaction documents, provided such amounts are fully recovered with interest accrued thereon prior to legal final maturity under the relevant rating stress.

Senior Subordinate, Shifting Interest Structure: The mortgage cash flow and loss allocation are based on a senior sub, shifting interest pay structure, whereby subordinate classes receive only scheduled principal and are locked out of receiving unscheduled principal or prepayments for the first five years. The lockout feature helps maintain subordination for a longer period should losses occur later in the life of the deal. The applicable credit support percentage feature redirects subordinate principal to classes of higher seniority if specified CE levels are not maintained. Fitch views this structure as consistent with an 'Asf' rating for RPL transactions.

PD Adjustment for Clean Current Loans: Fitch's analysis of the performance of clean current loans - i.e. loans with clean payment histories for the past 24 months - found that its loan loss model projected probability of defaults (PDs) for those loans were more punitive than those indicated by Fitch's roll rate projections. To account for this, Fitch reduced the lifetime default expectations by approximately 21% at 'Asf' for the all of the loans, since 100% have been current for the past 36 months.

Extended Foreclosure Timelines: Fitch increased its foreclosure timeline assumptions for all loans by an additional six months due to the likelihood that RPLs may enter foreclosure relatively quickly and, therefore, be subject to the long timelines reflective of today's liquidation/foreclosure environment rather than the shorter timelines expected for newly originated loans that are not likely to enter default for a few years.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate how the ratings would react to steeper market value declines (MVDs) than assumed at both the metropolitan statistical area (MSA) and national levels. The implied rating sensitivities are only an indication of some of the potential outcomes and do not consider other risk factors that the transaction may become exposed to or be considered in the surveillance of the transaction.

Fitch conducted sensitivity analysis determining how the ratings would react to steeper MVDs at the national level. The analysis assumes MVDs of 10%, 20%, and 30%, in addition to the model-projected 5.7% for this pool. The analysis indicates there is some potential rating migration with higher MVDs, compared with the model projection.

Fitch also conducted sensitivities to determine the stresses to MVDs that would reduce a rating by one full category, to non-investment grade, and to 'CCCsf'.

Additional information is available at 'www.fitchratings.com'.

In addition to the information sources identified in Fitch's criteria listed below, Fitch's analysis incorporated data tapes, due diligence results, deal structure and legal documents from the 17g5 website available on 'www.debtdomain.com'.

Applicable Criteria and Related Research

--'Global Structured Finance Rating Criteria' (May 2014);

--'Counterparty Criteria for Structured Finance and Covered Bonds' (May 2014);

--'U.S. RMBS Master Rating Criteria' (July 2014);

--'U.S. RMBS Loan Loss Model Criteria' (November 2014);

--'U.S. RMBS Cash Flow Analysis Criteria' (April 2014);

--'U.S. RMBS Re-Performing Loan Criteria' (November 2014)

--'Rating Criteria for U.S. Residential and Small Balance Commercial Mortgage Servicers' (January 2014);

--'U.S. RMBS Surveillance and re-REMIC Criteria' (June 2014);

--'U.S. RMBS Qualified and Non-Qualified Mortgage Criteria' (March 2014).

Additional Disclosure

Solicitation Status

http://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=982530

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Contacts

Fitch Ratings
Primary Analyst:
Roger Lin, +1-212-908-0778
Director
Fitch Ratings, Inc.
33 Whitehall Street
New York, NY 10004
or
Secondary Analyst:
Suzanne Mistretta, +1-212-908-0639
Senior Director
or
Committee Chairperson:
Roelof Slump, +1-212-908-0075
Managing Director
or
Sandro Scenga, +1-212-908-0278
Media Relations, New York
sandro.scenga@fitchratings.com

Contacts

Fitch Ratings
Primary Analyst:
Roger Lin, +1-212-908-0778
Director
Fitch Ratings, Inc.
33 Whitehall Street
New York, NY 10004
or
Secondary Analyst:
Suzanne Mistretta, +1-212-908-0639
Senior Director
or
Committee Chairperson:
Roelof Slump, +1-212-908-0075
Managing Director
or
Sandro Scenga, +1-212-908-0278
Media Relations, New York
sandro.scenga@fitchratings.com