Correction: Fitch Expects to Rate Towd Point Mortgage Trust 2015-6; Presale Issued

NEW YORK--()--(This is a correction of a release originally published Nov. 18, 2015. It corrects the description of the liquidation timelines assumptions.)

Fitch Ratings expects to rate Towd Point Mortgage Trust 2015-6 (TPMT 2015-6) as follows:

--$515,247,000 class A1 notes 'AAAsf'; Outlook Stable;

--$58,187,000 class A2 notes 'AAsf'; Outlook Stable;

--$54,190,000 class M1 notes 'Asf'; Outlook Stable;

--$48,860,000 class M2 notes 'BBBsf'; Outlook Stable;

--$42,641,000 class B1 notes 'BBsf'; Outlook Stable;

--$37,755,000 class B2 notes 'Bsf'; Outlook Stable;

--$58,187,000 class A2A exchangeable notes 'AAsf'; Outlook Stable;

--$54,190,000 class M1A exchangeable notes 'Asf'; Outlook Stable;

--$48,860,000 class M2A exchangeable notes 'BBBsf'; Outlook Stable

--$58,187,000 class A2X notional exchangeable notes 'AAsf'; Outlook Stable;

--$54,190,000 class M1X notional exchangeable notes 'Asf'; Outlook Stable;

--$48,860,000 class M2X notional exchangeable notes 'BBBsf'; Outlook Stable;

--$515,247,000 class A1A exchangeable notes 'AAAsf'; Outlook Stable;

--$515,247,000 class A1B exchangeable notes 'AAAsf'; Outlook Stable;

--$515,247,000 class A1C exchangeable notes 'AAAsf'; Outlook Stable;

--$515,247,000 class X1 notional exchangeable notes 'AAAsf'; Outlook Stable;

--$515,247,000 class X2 notional exchangeable notes 'AAAsf'; Outlook Stable;

--$515,247,000 class X3 notional exchangeable notes 'AAAsf'; Outlook Stable;

--$573,434,000 class A3 exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class A3A exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class A3B exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class A3C exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class X4 notional exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class X5 notional exchangeable notes 'AAsf'; Outlook Stable;

--$573,434,000 class X6 notional exchangeable notes 'AAsf'; Outlook Stable;

--$627,624,000 class A4 exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class A4A exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class A4B exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class A4C exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class X7 notional exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class X8 notional exchangeable notes 'Asf'; Outlook Stable;

--$627,624,000 class X9 notional exchangeable notes 'Asf'; Outlook Stable;

The following classes will not be rated by Fitch:

--$65,738,000 class B3 notes;

--$65,739,244 class B4 notes.

Fitch has amended its presale on TPMT 2015-6 to correct the description of an extension to the liquidation timelines on all loans beyond the standard timelines described in Fitch's published criteria. The timeline extension was not applied in the analysis of this transaction. Fitch felt comfortable with the transaction's proposed credit enhancement levels without the additional timeline extension due to the high levels of loss protection relative to Fitch's base-case loss estimate, the significant percentage of the pool with more than two years clean payment history and the high percentage of the mortgage pool with clean due diligence results.

The notes are supported by one collateral group that consisted of 4,825 seasoned performing and re-performing mortgages with a total balance of approximately $888.4 million (which includes $37.7 million, or 4.2 %, of the aggregate pool balance in non-interest-bearing deferred principal amounts) as of the cut-off date.

The 'AAAsf' rating on class A1 notes reflects the 42.00% subordination provided by the 6.55% class A2, 6.10% class M1, 5.50% class M2, 4.80% class B1, 4.25% class B2, 7.40% class B3 and 7.40% class B4 notes.

Fitch's ratings on the class notes reflect the credit attributes of the underlying collateral; the quality of the servicers, Select Portfolio Servicing, Inc. (rated 'RPS1-') and Wells Fargo Home Mortgage (rated 'RPS1-'); the representation (rep) and warranty framework; minimal due diligence findings and the sequential pay structure.

KEY RATING DRIVERS

Distressed Performance History: The collateral pool consists primarily of peak-vintage seasoned re-performing loans (RPLs), including loans that have been paying for the past 24 months, which Fitch identifies as 'clean current' (75.9%), and loans that are current but have recent delinquencies identified as 'dirty current' (24.1%). All loans were current as of the cutoff date, and no loans were past due 90 or more days over the past 24 months. 78.4% of the loans have received modifications.

'D' Grade for Compliance/High-Cost Testing: The third-party review (TPR) firm's due diligence review resulted in 315 loans graded 'D', the majority of which had late fee charges that violated state regulation or had HUD1 Settlement Statement (HUD1) exceptions. For 235 loans (4.9%), the due diligence results showed issues regarding high cost testing; the loans were either missing the final HUD1 or used alternate documentation to test. Therefore a slight upwards revision to the model output loss severity (LS) was applied, as further described in Appendix D of the Towd Point Mortgage Trust 2015-6 Presale Report.

No Servicer P&I Advances: The servicer will not be advancing delinquent monthly payments of principal and interest (P&I). As P&I advances made on behalf of loans that become delinquent and eventually liquidate reduce liquidation proceeds to the trust, the loan-level loss severities (LS) are less for this transaction than for those where the servicer is obligated to advance P&I. Structural provisions and cash flow priorities, together with increased subordination, provide for timely payments of interest to the 'AAAsf' and 'AAsf' rated classes.

Sequential-Pay Structure: The transaction's cash flow is based on a sequential-pay structure, whereby the subordinate classes do not receive principal until the senior classes are repaid in full. Losses are allocated in reverse-sequential order. Furthermore, the provision to re-allocate principal to pay interest on the 'AAAsf' and 'AAsf' rated notes prior to other principal distributions is highly supportive of timely interest payments to those classes, in the absence of servicer advancing.

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 the most senior outstanding.

Under Fitch's 'Criteria for Rating Caps and Limitations in Global Structured Finance Transactions,' published in May 2014, the agency may assign ratings of up to 'Asf' on notes that incur deferrals if such deferrals are permitted under 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.

Limited Life of Rep Provider: Cerberus Global Residential Mortgage Opportunity Fund, L.P., as rep provider, will only be obligated to repurchase a loan due to breaches that are identified as having breaches prior to the payment date in December 2016. Thereafter, a reserve fund will be available to cover amounts due to noteholders for loans identified as having rep breaches. Amounts on deposit in the reserve fund, as well as the increased level of subordination, will be available to cover additional defaults and losses resulting from rep weaknesses or breaches occurring after December 2016.

Tier 2 Representation Framework: Fitch generally considers the representation, warranty and enforcement (RW&E) mechanism construct for this transaction to be generally consistent with a Tier 2 framework due to the inclusion of knowledge qualifiers and the exclusion of loans from certain reps as a result of third-party due diligence findings. Thus, Fitch increased its 'AAAsf' loss expectations by 273 bps to account for a potential increase in defaults and losses arising from weaknesses in the reps.

Timing of Recordation and Document Remediation: An updated title and tax search, as well as a review to confirm that the mortgage and subsequent assignments were recorded in the relevant local jurisdictions, was also performed. Per the representations provided in the transaction documents all loans have either all been recorded in the appropriate jurisdiction, are in the process of being recorded, or will be sent for recordation within 12 months of the closing date.

While the expected timelines for recordation and remediation are viewed by Fitch as reasonable, Fitch believes that FirstKey's oversight for completion of these activities serves as a strong mitigant to potential delays. In addition, the obligation of Cerberus Global Residential Mortgage Opportunity Fund, L.P. to repurchase loans, for which assignments are not recorded and endorsements are not completed by the payment date in December 2016, aligns the issuer's interests regarding completing the recordation process with those of noteholders.

PD Adjustment for Clean Current Loans: Fitch's analysis of the performance of clean current loans found that, for these loans, its loan loss model projected probability of defaults (PDs) that were more punitive than indicated by Fitch's roll rate projections. To account for this, Fitch reduced the lifetime default expectations by approximately 16.4% for the loans that have a clean payment history for at least the past 24 months.

Deferred Amounts: Non-interest-bearing principal forbearance amounts totaling $37.7 million (4.2% of the unpaid principal balance) are outstanding on 896 loans. Fitch included the deferred amounts when calculating the borrower's LTV and sLTV, despite the lower payment and amounts not being owed during the term of the loan. The inclusion resulted in higher PDs and LS than if there were no deferrals. Fitch believes that borrower default behavior will resemble that of the higher LTVs, including the deferred balances, as exit strategies (i.e. sale or refinancing) will be limited relative to those borrowers with more equity in the property.

Third-Party Loan Sale Provisions: The transaction permits nonperforming loans and loans classified as real estate-owned (REO) to be sold to unaffiliated third parties to maximize liquidation proceeds to the issuer. FirstKey as asset manager is charged with responsibility for arranging such sales. To ensure that loan sales do not result in losses to the trust that exceed Fitch's expectations, the sale price is floored at a minimum value equal to 55.64% of the unpaid principal balance, which approximates Fitch's 'Bsf' LS expectations.

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%. 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'.

DUE DILIGENCE USAGE

Fitch was provided with due diligence information, as well as the final Form 15E, from Avenue365, Clayton, American Mortgage Consultants (AMC) and JCIII & Associates (JCIII). The due diligence focused on regulatory compliance, pay history, servicing comments, the presence of key documents in the loan file and data integrity. In addition, Avenue365 and JCIII (Stewart Lender Services provided reports) were retained to perform an updated title and tax search, as well as a review to confirm that the mortgages were recorded in the relevant local jurisdiction and the related assignment chains.

The servicing comment review was completed on sample (approximately 29% of the loans). 86% have been current for the past 12 months (and some for 36 months) and were confirmed via the pay history review to be as such. Given this performance, Fitch determined it to be a mitigating factor to the sample size and that no additional adjustments were needed.

Fitch considered this information in its analysis and based on the findings, Fitch made minor adjustments to its analysis. 134 loans were found to have an exception due to missing modification documents or a missing signature on modification documents. For these loans, timelines were extended by three months.

235 loans were graded 'D' and were eligible for federal, state, and/or local predatory testing. These loans contained material violations including an inability to test for high cost violations or confirm compliance. Typically the HUD issues are related to missing Final HUD, illegible HUDs, incomplete HUDs due to missing pages, or only having estimated HUDs. A final HUD1 was not used to test for High Cost loans. To mitigate this risk, Fitch assumed a 100% loss severity for loans in states that fall under Freddie Mac's do not purchase list of 'high cost' or 'high risk'. Currently, 14 states are on this list are AR , CO , GA , IL , IN , KY , ME , MA , NJ , NM , NY , OK , RI , and TN. 25 loans were impacted by this approach.

For the remaining 36 states where a final HUD1 was not used, the likelihood of all loans being high cost is lower. However, Fitch assumes the trust could potentially incur notable legal expenses. Fitch assumed damages (points and fees, interest, and the maximum statutory damages allowed under TILA and borrower legal costs) for successful borrower challenges, and made an adjustment to the loss severity to mitigate this risk. 210 loans were impacted by this approach.

Additional information is available at www.fitchratings.com.

Towd Point Mortgage Trust 2015-6 -- Amended

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=874524

Applicable Criteria

Counterparty Criteria for Structured Finance and Covered Bonds (pub. 14 May 2014)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=744158

Criteria for Rating Caps and Limitations in Global Structured Finance Transactions (pub. 28 May 2014)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=748781

Global Structured Finance Rating Criteria (pub. 06 Jul 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=867952

Rating Criteria for U.S. Residential and Small Balance Commercial Mortgage Servicers (pub. 23 Apr 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=864368

U.S. RMBS Cash Flow Analysis Criteria (pub. 06 Apr 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=863973

U.S. RMBS Loan Loss Model Criteria (pub. 03 Aug 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=868923

U.S. RMBS Master Rating Criteria (pub. 01 Oct 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=870427

U.S. RMBS Qualified and Non-Qualified Mortgage Criteria (pub. 31 Mar 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=863837

U.S. RMBS Surveillance and Re-REMIC Criteria (pub. 01 Jun 2015)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=866259

US RMBS Re-Performing Loan Criteria (pub. 21 Nov 2014)

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=811488

Related Research

Towd Point Mortgage Trust 2015-6 - Appendix

https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=873946

Additional Disclosures

Dodd-Frank Rating Information Disclosure Form

https://www.fitchratings.com/creditdesk/press_releases/content/ridf_frame.cfm?pr_id=995372

ABS Due Diligence Form 15E 1

https://www.fitchratings.com/creditdesk/press_releases/content/ridf15E_frame.cfm?pr_id=995372&flm_nm=15e_995372_1.pdf

ABS Due Diligence Form 15E 2

https://www.fitchratings.com/creditdesk/press_releases/content/ridf15E_frame.cfm?pr_id=995372&flm_nm=15e_995372_2.pdf

ABS Due Diligence Form 15E 3

https://www.fitchratings.com/creditdesk/press_releases/content/ridf15E_frame.cfm?pr_id=995372&flm_nm=15e_995372_3.pdf

ABS Due Diligence Form 15E 4

https://www.fitchratings.com/creditdesk/press_releases/content/ridf15E_frame.cfm?pr_id=995372&flm_nm=15e_995372_4.pdf

ABS Due Diligence Form 15E 5

https://www.fitchratings.com/creditdesk/press_releases/content/ridf15E_frame.cfm?pr_id=995372&flm_nm=15e_995372_5.pdf

Solicitation Status

https://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=995372

Endorsement Policy

https://www.fitchratings.com/jsp/creditdesk/PolicyRegulation.faces?context=2&detail=31

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY'S PUBLIC WEBSITE 'WWW.FITCHRATINGS.COM'. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH'S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE 'CODE OF CONDUCT' SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.

Contacts

Fitch Ratings
Primary Analyst
Susan Hosterman
Director
+1-212-908-0670
Fitch Ratings, Inc.
33 Whitehall Street
New York, NY 10004
or
Secondary Analyst
Rachel Noonan
Director
+1-212-908-0224
or
Committee Chairperson
Suzanne Mistretta
Senior Director
+1-212-908-0639
or
Media Relations:
Sandro Scenga, +1 212-908-0278
sandro.scenga@fitchratings.com

Contacts

Fitch Ratings
Primary Analyst
Susan Hosterman
Director
+1-212-908-0670
Fitch Ratings, Inc.
33 Whitehall Street
New York, NY 10004
or
Secondary Analyst
Rachel Noonan
Director
+1-212-908-0224
or
Committee Chairperson
Suzanne Mistretta
Senior Director
+1-212-908-0639
or
Media Relations:
Sandro Scenga, +1 212-908-0278
sandro.scenga@fitchratings.com