News Analysis
Asset-Backed Finance
UK bridging loan RMBS market primed for growth
Enquiries around publicly rated deals rise as lenders eye more diverse sources of funding
Enquiries into European bridging loan RMBS securitisations are on the rise, with industry sources anticipating the UK will develop into the leading market for new issuance. With the US market leading the way, a shift from private to public could open the asset class up to new investors.
“We’ve had a number of enquiries on the feasibility of doing bridging loan securitisations,” says Alastair Bigley, md and sector lead for European RMBS at S&P Global.
Thus far, all European bridging loan issuance has been private. However, with the US making history earlier this year with the first publicly rated bridging loan securitisation, things could be set for a change on this side of the pond too.
“The US is the most established market and has the most esoteric, non-vanilla asset classes,” explains Bigley. “The fact a deal has been done in the US could signify that there is now a benchmark in place – and people often look to the US when it comes to figuring out what could be the next big thing in securitisation.”
While the UK market may be at the front of the line in terms of anticipated market action, the evolving bridging-loan-backed securitisation market is not just a UK phenomenon, but one that exists worldwide. Bigley explains: “Commercial banks across the continent will have an asset similar to this, but the market is likely bigger in the UK, probably because property speculation and development are more ingrained in the UK than they are in some continental European countries.”
Many forms of lending fall under the bridging loan umbrella. These include multiple different forms of loans for owner occupation, from chain breaking and fast purchase to even preventing repossession. Most recent annual figures show the UK’s bridging loan market sat at an estimated total of £7.6bn for 2023, with the average loan book at around £250m for each lender.
“It’s just one of these markets that’s been hidden from public view,” says Bigley. “It’s not a new market per se. Property development and buying property at auctions has been around for decades, but it’s been funded directly on banks’ balance sheets – and now that’s changing a little bit. Many non-banks with different funding models are active in the bridging space, particularly in the UK.”
With active private markets in many jurisdictions, such as the Netherlands, UK and US, the bridging loan RMBS market now has a benchmark for the first time, following the issuance of the first publicly rated transaction in the US.
S&P estimates somewhere north of 50 lenders to be active in the bridging loan space in the UK. While many bridging lenders in the country still lack the scale to utilise securitisation as a means of increasing their funding diversity or securing potential pricing pickups, some of the larger ones do.
“There’s all sorts of subtle reasons why it could be done – but I would expect for the larger lenders, diversification is the main objective here,” explains Bigley. “Bridging lenders can be funded in different ways, but the larger ones would likely be financed with a warehouse in a larger bank, which would in effect look like a securitisation. Smaller ones might be funded by family officers or directly by their equity investors.”
Therefore, while many bridging lenders are reportedly interested in increasing the diversity of their funding, only larger lenders have the scale to efficiently adopt securitisation technology as a means of securing this diversification. It also may not be too much of a stretch to get lenders equipped for investing in bridging loan RMBS, according to Bigley, as many participants are already involved in both spaces – including players like LendInvest.
“If you look at who the bridging lenders are, a lot of them are existing RMBS issuers,” explains Bigley. “So a lot of the bridging lenders are already familiar with securitisations. It’s one of those markets where the knowledge is already within these institutions to be able to do it.”
While the knowledge may already exist within the market, many barriers to entry remain – including structural challenges born out of the nature of bridging loans. “They are a very short duration asset,” says Bigley. “To overcome that in a securitisation, you likely need to come up with some level of revolving feature – and how that is controlled is an additional issue.”
He continues: “The other element is that a lot of the underlying assets don’t pay interest on an ongoing basis – it’s rolled up as you go through the loan, rather than monthly as you would with a typical mortgage.”
Additionally, while bridging-loan-backed transactions may look similar to RMBS deals, trying to liquidate partially completed construction projects rather than standard residential homes is a different prospect. However, exactly how a ‘bridging loan’ is defined varies, and as the market grows Bigley expects it to continue to evolve.
“The phrase ‘bridging loan’ means a lot of things to a lot of different people,” he says. “On one end of it is relatively straightforward residential lending – someone wanting to buy a property on the right street quicker than anyone else. On the opposite end of it, it could be something like an undeveloped plot of land that’s 50% complete with half a building on it.”
However, despite the fact there is a sense of familiarity with the product amongst investors – who are likely to understand a transaction if it came in this form – much groundwork needs to be done before a public market is up and running in the UK.
Claudia Lewis
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News Analysis
CLOs
European CLO new issuance soars in Q1
Primary new issuance reaches highest level since Russia's invasion of Ukraine
European CLO primary new issuance has reached the highest level since the Russian invasion of Ukraine two years ago, which led to steep rises in inflation and central bank base rates.
The aggregate value of European deals reached €11.35bn in the first quarter of 2024, according to SCI data, the highest figure since the €12.97bn of new issuance witnessed in Q4 2021. The quarterly figure is also the second highest amount recorded by SCI over the past five years and the highest Q1 figure during that time frame. It marks a 69% increase compared with the same period in 2023.
New issuance has grown beyond the expectations of even a few months ago, says Andrew South, head of EMEA structured finance research at S&P Global Ratings. The ratings agency had been anticipating that issuance would be relatively flat compared with last year, he says. Instead, its team has been particularly active in recent months, given that it rates the majority of CLOs in Europe.
The trend is reflective of similar levels of activity in the US, according to S&P’s most recent US Structured Finance Chart Book, issued in March. The agency’s research showed US CLO new issuance in the first two months of the year reached US$33bn, compared with US$23bn last year and US$20bn in 2022.
“Banks and institutional funds continue to be actively investing in triple-As and double-As,” says Jonathon Siatkowski, head of CLO capital markets at Marathon Asset Management. “In 2022, and 2023 most large US banks were absent, but we have begun to observe banks coming back. With Basel III capital charge implementation later this year, we expect to see more sustained activity.”
He adds: “ETFs have entered the space as well and are increasingly involved players. Overseas triple-As like Japanese banks and European investors have gradually increased their investments for the last few years and are expected to continue their investing.”
Siatkowski says that within mezzanine tranches, insurance companies have shown strong interest, finding CLO double-A, single-A, and triple-B attractive on a relative value basis compared to ABS and fixed rate corporate bonds.
“Most notably, the net interest margin available for CLO equity improved dramatically as spreads snapped in, resulting in CLO equity models producing much stronger front-end cash-on-cash distributions,” says Siatkowski. “This has led to robust interest for equity, including minority equity.”
Despite the significant uplift in European issuance since the start of the year, S&P’s South points to the resilience of the market throughout 2023. He highlights how approaches may evolve as lending markets return and the macroeconomic picture continues to stabilise.
“Last year, issuance surprised to the upside too,” says South. “If you looked at how little leveraged loan issuance was going on, the fact that CLO issuance was where it was — at around €26bn – was a bit surprising. It was a function of managers innovating by buying more in the secondary market for example.”
Last year was broadly a case of emptying warehouses that were already in place, South says. He says that, as a result, this year’s issuance was not expected to exceed those levels.
“Actually, it has been stronger than at this point last year, and that probably is driven by the recovery in the leveraged loan space,” says South. “In mid-2022, speculative grade corporate issuance fell off a cliff. That has recently recovered almost to longer-term average levels, and that clearly helps CLO issuance. It’s partly driven by slightly increased M&A activity, among other factors.”
Indeed, Baker McKenzie forecast in its Leveraged Finance Annual Report 2024, published in February, that M&A activity will return “with a vengeance” this year. The law firm anticipates that, as interest rates stabilise – albeit at higher levels than those seen between the global financial crisis and the start of the war in Ukraine – buyer and seller views around valuations will align. M&A activity, it says, will be “rekindled throughout the markets”.
However, Marathon’s Siatkowski highlights that the year ahead will bring uncertainty for CLO managers, as well as opportunities. “Oscillations in interest rate expectations, geopolitical concerns, and the upcoming US elections are likely to create pockets of volatility in the loan and CLO markets, which will create opportunity for new and recently issued CLOs,” he says. “This will support CLO equity capital supply, but with a preference for CLO managers with a track record over multiple cycles and CLO portfolios deemed to be more-conservative or defensive by market participants.”
Kenny Wastell
News Analysis
Capital Relief Trades
Double down
ASRS goes big in SRT in new mandate with AXA
Arizona State Retirement System (ASRS) will double its investment in SRT through its new US$400m mandate to AXA IM Alts, announced last week.
The US pension fund has been participating in risk sharing investments since 2019 through a partnership with Chorus Capital, but the new arrangement with AXA will increase, and, it is hoped, diversify exposure.
“As the SRT market has continued to grow and we have found very attractive returns in the asset class, we were looking for an additional manager to complement our very successful partnership with Chorus,” deputy chief investment officer Al Alaimo told SCI.
While Chorus has pursued SRT deals that collateralize investment grade loans, AXA will bring deals back by other forms of capital such as SME loans, CRE loans and trade finance. Possible returns in derived from these asset pools are likely to exceed returns from investment grade loans.
The new manager will also introduce ASRS to a fresh range of borrowers and relationships.
AXA has discretion to invest in SRTs across a wide variety of underlying loan types, and ASRS expects “net double digit returns,” says Alaimo.
"They source, originate and underwrite transactions. They generate a yield from the investments, which we receive, and they earn a management fee and an incentive fee, based on the return,” he explains.
If the SRT market changes to the extent that the kind of yields ASRS seeks are longer attainable then no investment in the market will be made.
ASRS started investing in the credit market after the financial crisis of 2008/2009 and then increased exposure through investment in private credit and direct lending. The fund is worth US$54bn and 23%, or around 12% is now, devoted to credit exposure.
It began looking at opportunities in risk sharing well before 2019, and tried to get a full understanding of the product. This makes the fund an early mover in SRT product in the US, and around 7% of its total credit allocation is now directed at risk sharing investments.
Chorus appealed to it as a manager with an extensive track record in the product and an experienced team dedicated solely to it, rather than a newer entrant with a more opportunistic approach.
AXA exhibits the same characteristics, according to Alaimo. “AXA has a strong track record, a great team and extensive experience in the asset class. This is a long term partnership. Initially, they have a US$400 mandate over a four year investment period but the partnership could go on for many years beyond that,” he says.
Lack of understanding, and opposition, from board members often holds up asset managers who are interested in SRT but this was not a problem for ASRS as all investment decisions are delegated to the staff lower down the totem pole. The board is not involved in this process.
Possible returns was clearly the factor that first aroused interest in SRT. “We are always looking for opportunities to diversify our portfolio and earn net returns of at least 9% or 10%,” says Alaimo.
Simon Boughey
SRT Market Update
Capital Relief Trades
Hey Magdalena
SRT Market Update
Santander is in the market with the latest SRT deal from its Magdalena programme. The deal will have a mixed tranche with both funded and unfunded elements.
In terms of innovations, the deals includes a revolving period where for six months after closing the bank will be able to add new loans but still keep the notional constant. Overall, the deal is believed to be “very similar” to its predecessor.
The Spanish bank has thus far issued seven deals from the Magdalena programme. Last September, Magdalena 7 referenced a €1.9bn portfolio of Spanish corporate, SME, and self-employed borrower loans. It had a WAL of 3.21 years and a final legal maturity of December 2044. The deal priced at three-month Euribor plus 10%, a 65bps tightening compared to Magdalena 6.
SCI understands that many of the new deal’s details are very similar to the previous one – however pricing may vary.
Joe Quiruga
SRT Market Update
Capital Relief Trades
Funded vs unfunded divide
SRT Market Update
This week investors and market insiders have highlighted a debate and disagreements regarding the future of unfunded SRT deals.
Commenting on the matter, one SRT investor notes: “The UK regulator doesn’t seem to like unfunded deals – it doesn’t ban them, but it makes them very complex. Doing an unfunded deal requires you to look abroad.”
Another investor further points to the lack of collateral in unfunded deals – which maintains the risk exposure of the seller and doesn’t help when looking for capital relief – as an additional explanation as to why funded trades remain the norm.
However, a third observer nuances those views noting, that while conventional wisdom agrees that funded transaction dominate the SRT market, (re)insurers are becoming a growing part of the market with many of the new investors entering the market coming from a (re)insurance background.
For instance Munich Re has built a sizeable war chest to put into 20 transactions over the course of the year. It was recently in talks with Nordea for an SRT deal referencing mortgages. A market observer suggests a second tranche was won by Arch.
One source suggests that Munich Re “have a lower cost of capital so will be looking at vanilla portfolios at a reasonable price. Corporate and SMEs would be good deals for it, but a mortgages deal didn’t surprise me as it allows Munich to max its liabilities for 15 years and get a nice stable fund with a low delinquency rate.”
Meanwhile looking at the upcoming pipeline, on the Wells Fargo deal, the issuer-to-be is known to have “a huge portfolio of conservative loans” to reference. Market sources further say that Société Générale could be among the issuers interested in coming to the table soon.
Regarding the US market specifically, banks looks to be ramping up for the, so far illusory, H2 issuing bonanza. Multiple sources have said the delay in issuance which came after the series of Q1 deals is not related to political risk surrounding the US election.
“People don’t generally favour uncertainty, and there is a risk of volatility for the second half of the year. But what is obvious is that any CRT deal is a matter of regulatory capital treatment meaning you need to make sure proposals are feasible,” one source observes.
He concludes: “As such it’s more a matter of regulation rather than politics and the only way the election would have an impact is if a change of president means a change of regulations. I have no view on this, but will say the Fed has become much more accepting of CRT deals recently.”
Joe Quiruga
News
Structured Finance
GSE results, tender
Profits up at both GSEs
Fannie Mae profits climbed 10.3% in Q1 to US$4.3bn, despite a 11.4% decline in acquisitions of single-family mortgages, according to its earnings call this week. The GSE also recorded a $180m benefit for credit losses in Q1 after taking a US$116m provision for credit losses in Q4 2023. There was a US$155m provision for losses in the multi-family business due to higher interest rates and declining property values.
Earlier in the week the GSE also announced it has successfully tendered US$1.7bn of seven old CAS securities issued in 2017, 2018, 2019 and 2020. The tender offer period concluded at 5pm in New York, 26th April. Five B1s and two M2s were available for tender, and the amounts offered varied between 4.63% and 100% of the original issue sale. In total, 91.8% of the original issuance was successfully tendered. Bank of America Securities acted as the designated lead dealer manager and Wells Fargo Securities acted as the designated dealer manager for the offers.
Freddie Mac also announced this week that Q1 net income increased by US$377m compared to Q4 2024, primarily as a result of a shift to fair value gains and a benefit for credit losses. This was partially offset by a decrease in net interest income. The net worth of the GSE increased over US$4bn from the end of 2023 to US$82bn.
Simon Boughey
News
Capital Relief Trades
A long-awaited sequel
SRT Market Update
Bank of Ireland is releasing a third Mespil SRT transaction. Features of the deal include an 8.5% attach tranche and both a funded and unfunded portion. Additionally, the transaction benefits from synthetic excess spread.
Both of the previous deals in the series have referenced a portfolio of leveraged loans.
Joe Quiruga
News
Capital Relief Trades
Exclusive mandate
RCQ associates point to high demand for CRT specialists
Structured credit head-hunters RCQ Associates (RCQ) have an exclusive mandate to help boost Bank of Montreal’s (BMO) CRT department in Toronto as North American issuers ready themselves for a busy second half of the year.
Edward James, founding director of RCQ, says: “We’re conducting an international search for people looking to make that move in Toronto. The skillsets are in high demand and Toronto has a high appeal as an anglophone environment with interesting and varied roles as well as a strong total compensation package.”
He adds that, while some in the industry have complained of a skill’s gap between CRT specialists and those who work on other forms of structured credit, this is less of a problem for him: “Specialised head hunters find the right people.”
Other sources have indicated this is likely a replacement of CRT specialists who are leaving rather than increasing the size of the department in a bid to do increase CRT issuance for this year. But this nonetheless indicates the health of the market as other Canadian banks have recently come online – and further point to strong demand for talent in this space.
BMO were the first Canadian issuers of CRT with deals as early as 2017, although Barclays’ Colonnade Global 2016-1 deal referenced some Canadian assets. BMO has since been joined by at least three more of the five major Canadian banks with Toronto Dominion, CIBC and Bank of Novia Scotia all issuing in 2023.
One source observes BMO has “a few programmes out there” and may be looking to new investors to diversify its concentration.
Joe Quiruga
News
SRTx
Latest SRTx fixings released
Following a strong Q1, the April indexes point to rising geo-political risks and higher rates in the US.
The latest fixings for the SRTx (Significant Risk Transfer Index) have been released. In a shift from last month (SCI 10 April), volatility, liquidity and credit risk indexes all indicate a general shift in risk appetite.
SRTx Spread Indexes have displayed some moderate widening in the SME segment (+1.2% in Europe and +1.1% in the US). Regarding the large corporate category, Europe remained unmoved while the US saw a slight variation (-0.8%). Overall, the sentiment on spreads witnessed little change.
The SRTx Spread Indexes now stand at 931, 763, 1,050 and 1,125 for the SRTx CORP EU, SRTx CORP US, SRTx SME EU and SRTx SME US categories respectively, as of the 2 May valuation date.
SRTx Volatility Index values have migrated back towards more balanced figures, indicating a riskier sentiment in the market month-on-month. In this context, the European and US large corporate segments have widened the most (+30.8% and +30.0%, respectively). Similarly for the SME sector, results show a moderate tightening (+21.4% in Europe and +12.5% in the US).
The SRTx Volatility Index values now stand at 53, 54, 53 and 56 for the SRTx CORP VOL EU, SRTx CORP VOL US, SRTx SME VOL EU and SRTx SME VOL US indexes respectively. Nevertheless, with these figures sitting around the 50 benchmark, volatility remains balanced overall.
On the liquidity front, the SRTx Liquidity Indexes equally reflect a shift towards increased risk. The US (+80.0%) SME value tightened most significantly (+15.4% in Europe), while the large corporate SRT values similarly increased (+15.4% in Europe and +33.3% in the US).
The SRTx Liquidity Indexes stand at 47, 50, 47 and 56 across SRTx CORP LIQ EU, SRTx CORP LIQ US, SRTx SME LIQ EU and SRTx SME LIQ US respectively.
Finally, The SRTx Credit Risk Indexes reveal a comparable trend. Except for the EU SME segment (-16.7% as opposed to +11.1% in the US), all other figures point to a shift – although the figures still sit around the 50 benchmark – towards right-leaning, riskier sentiment (+6.7% for European large corporate and +27.3% in the US).
The SRTx Credit Risk Indexes now stand at 50 for SRTx CORP RISK EU, 58 for SRTx CORP RISK US, 47 for SRTx SME RISK EU and 63 for SRTx SME RISK US.
SRTx coverage includes large corporate and SME reference pools across the EU and US economic regions. The index suite comprises a quantitative spread index - which is based on survey estimates for a representative transaction (the SRTx Benchmark Deal) that has specified terms for structure and portfolio composition - and three qualitative indexes, which measure market sentiment on pricing volatility, transaction liquidity and credit risk.
Specifically, the SRTx Volatility Indexes gauge market sentiment for the magnitude of fixed-spread pricing volatility over the near term. The index scale is 0-100, with levels above 50 indicating a higher proportion of respondents estimating volatility moving higher.
The SRTx Liquidity Indexes gauge market sentiment for SRT execution conditions in terms of successfully completing a deal in the near term. Again, the index scale is 0-100, with levels above 50 indicating a higher proportion of respondents estimating that liquidity is worsening.
Finally, the SRTx Credit Risk Indexes gauge market sentiment on the direction of fundamental SRT reference pool credit risk over the near term. The index scale is 0-100, with levels above 50 indicating a higher proportion of respondents estimating that credit risk is worsening.
The objective of the index suite is to depict changes in market sentiment, the magnitude of such change and the dispersion of market opinion around volatility, liquidity and credit risk.
The indexes are surveyed on a monthly basis and recalculated on the last trading day of the month. SCI is the index licensor and the calculation agent is Mark Fontanilla & Co.
For further information on SRTx or to register your interest as a contributor to the index, click here.
Vincent Nadeau
Market Moves
Structured Finance
PRA and FCA confirm new UK securitisation rules
Market updates and sector developments
The Financial Conduct Authority’s (FCA) and Prudential Regulation Authority (PRA) have published policy statements on new securitisation rules. Alongside the UK Treasury’s draft statutory instrument on securitisation, which was published last week, the changes will come into force on 1 November and will replace EU securitisation regulations.
The PRA’s statement was published alongside the Securitisation Instrument 2024 section of the PRA Rulebook.
The publication of the documents follow consultations on proposed plans published by the PRA and FCA in July 2023 and August 2023 respectively, while the government also presented its “near final” statutory instrument and policy note in July. Implementation was initially scheduled for Q2 of 2024.
Following those publications, industry sources told SCI that there appeared to be some welcome changes to retained regulations ‘onshored’ after Brexit, but that the British government was unlikely to secure the bonfire of regulations it had set out to achieve (SCI 15 August 2023).
The PRA said it received “largely supportive” responses to its 2023 consultation, though there were “a number of requested changes”. These included a delay to the implementation date, better alignment between FCA and PRA rules drafting, and transitional provisions for impacted securitisations that were set up prior to the implementation of the proposed new rules. The PRA said all of these areas have been addressed, while it has also responded to requests for clarification in other areas.
In a statement, PCS said it would be “reading both with interest, as will no doubt all market participants with an interest in UK transactions”.
In other news…
New York Mortgage Trust selects Computershare
Computershare Corporate Trust (formerly known as Wells Fargo CTS) has rolled out its new RMBS trustee services, with New York Mortgage Trust (NYMT) becoming the team’s first client. NYMT has appointed Computershare as indenture trustee for NYMT 2024-BPL1, with the provider also providing document custodian, securities administrator and paying agent services on the transaction.
Kenny Wastell
Market Moves
Structured Finance
Job swaps weekly: Ashurst lures Fried Frank trio
People moves and key promotions in securitisation
This week’s roundup of securitisation job swaps sees Ashurst hiring three structured products professionals, including a partner, from Fried Frank. Elsewhere, Capital Four’s US ceo has left the firm after three years, while HFW has appointed two executives from Norton Rose Fulbright to its global shipping and export finance practice.
Ashurst has made three appointments to its US structured products, derivatives and complex financial products team, including the hiring of Fried Frank’s Nick Allen as partner, working out of New York. The trio were all part of the 20-strong team of lawyers Fried Frank poached from Cadwalader Wickersham & Taft in February 2022.
Allen leaves his role as special counsel at Fried Frank and previously spent nine years at Cadwalader. He advises banks, asset managers and hedge funds across a range of derivatives and financial products transactions.
The firm has also hired Andrea Stanovic and Juan Franco as associates from Fried Frank. Stanovic spent a combined two and a half years at Cadwalader, while Franco spent seven months with the firm, prior to the trio’s move to Fried Frank.
Meanwhile, Capital Four’s US ceo Jim Wiant, who also served as partner and a portfolio manager focusing on CLOs and US high yield, has left the firm after three years. Wiant joined the Danish credit manager in early 2021 in order to establish and lead the firm’s US office, after 12 years at MidOcean Partners. Capital Four was yet to reply to a request for comment from SCI at the time of publication.
HFW has hired Norton Rose Fulbright pair Paolo Pinna and Constance Ollat as partner and associate respectively in its global shipping and export finance practice, working out of the firm’s Paris office.
Pinna leaves his role as counsel at Norton Rose Fulbright after a cumulative 11 years with the firm across two spells. HFW said he advises on “English, French and Italian law” and on “international aspects of banking and finance transactions”, including asset finance, ECA and project finance, infrastructure finance, structured finance, lease transactions, and restructuring.
Ollat joins after six years at Norton Rose and Fulbright, most recently in the role of associate.
Credit and political risk insurance broker BPL has appointed Marsh’s Lizzie Thomas as a director, covering both the European and US markets. Thomas will be based in the company’s London office and will report to deputy ceo James Reynolds. She leaves her role as lenders solutions group leader for the UK – credit specialties at Marsh after 10 years with the firm.
The development comes shortly after Marsh announced the elevation of Christophe Letondot to the head of its newly launched global alternative risk solutions division. The division will work alongside Guy Carpenter to access capital pools including in the insurance linked securities market.
Letondot has been with Marsh since 2015 and is promoted from practice leader for the US and Canada credit specialties team, where he focused on alternative risk transfer, structured credit and parametric solutions. He will report to Pat Donnelly, president of Marsh specialty and global placement, and is based in New York.
White & Case has appointed Linklaters’ Eriko Sakata as a funds partner, based in Tokyo. Sakata has experience in real estate, infrastructure, financial regulation and structured finance. She leaves her role as partner at Linklaters after 12 years with the firm’s Tokyo office.
And finally, Paul Hastings leveraged finance partner Luke McDougall has joined Davis Polk as a partner in the firm’s finance practice, working out of its London office. McDougall leaves Paul Hastings after nine years with the firm, having previously worked at Ashurst and Minter Ellison.
Kenny Wastell
structuredcreditinvestor.com
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