Page 14 - MTIA Summer 2022 Market Brief
P. 14

CLO 3.0 structures offer          Structural Impacts
               managers enhanced flexibility     The use of CLO structures is evolving, with asset managers and insurers using
               compared to CLO 2.0,              balance sheet CLOs and CLOs finding applications within business development
                                                 companies (BDCs) for longer-term financing. There has also been a notable shift
               particularly in handling workouts
                                                 towards more loan-format liabilities versus bonds in CLO structures.
               and restructurings in response
               to default or restructuring       As the CLO landscape evolves, market participants must navigate complexities
               scenarios. Service providers      such as payment processing needs, data, reporting, and regulatory requirements.
                                                 Increasingly, CLO managers require service providers that can accommodate
               are being called upon to expand
                                                 needs such as complex excess calculations, virtual loan advance rates/contracts,
               their operational support         various asset haircuts, waterfall diversions, or unique loan investment criteria
               for CLOs, although the loan       reporting.
               market remains largely manual.
                                                 CLO transaction documents specify all reporting requirements based on the
               Achieving widespread efficiency   regulatory regimes relevant to the parties involved, including EU regulations,
               gains requires buy-in from all    the UK’s Financial Conduct Authority (FCA), and the Securities and Exchange
               market participants.              Commission (SEC) in the U.S.

                                                 Working With Data Gaps

                                                 Often, the required data exceeds what CLO trustees typically and historically
                                                 provided. Trustees work with third-party reporting providers on timing,
                                                 formatting, and data fields to supply transaction- related items, including cash
                                                 and par. In addition, the reports can include loan-level data such as EBITDA
                                                 and debt coverage from other sources, including borrowers, lenders, and rating
                                                 agencies.


                                                 For broadly syndicated loans, reporting information and underlying financial
                                                 data are more widely available (see “Tech in the Balance”). In the middle market,
                                                 with the dominance of private credit, such information is not widely published.
                                                 Trustees handle overall global and portfolio-level information and data from
                                                 routine activities such as payments, purchases, sales, and notices. CLO managers
                                                 own loan-level data, such as financial statements of underlying borrowers.


                                                 Collaboration Needed
                                                 Asset Managers use a wide array of systems to track and manage their portfolios,
                                                 resulting in non-standardized data sets. These variances require CLO managers,
                                                 administrative providers, and reporting providers to collaborate and develop
                                                 reliable mechanisms for delivering the required reports using various templates.
                                                 A lot of coordination occurs to address requirements not explicitly required or
                                                 documented under the original transactional agreements.

                                                 Trustees’ ability to automate the ingestion and provision of data can help
                                                 streamline the process. Furthermore, they need the flexibility and resources to
                                                 reconcile data issues accurately and in a timely manner. Collectively, all parties
                                                 need to come together to find ways to reduce the level of effort and the need for
                                                 manual intervention in the data to deliver reports on time and at a lower cost.







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