Rating Action Commentary
ֳ Assigns NewDay Funding's Series 2024-3 Notes Expected Ratings
Tue 15 Oct, 2024 - 11:35 AM ET
ֳ - London - 15 Oct 2024: ֳ has assigned NewDay Funding Master Issuer Plc's series 2024-3's notes expected ratings. The assignment of final ratings is contingent on the receipt of final documentation conforming to information already reviewed.
ֳ expects to affirm NewDay Funding's existing series when it assigns series 2024-3 final ratings.
Transaction Summary
The notes issued by NewDay Funding Master Issuer Plc are collateralised by a pool of non-prime UK credit card receivables originated by NewDay Limited (NewDay). NewDay is one of the largest specialist credit card companies in the UK, and offers cards both under its own brands and in partnership with individual retailers. Only the cards branded by NewDay, which are targeted at higher-risk borrowers on average, are included in this transaction. The cards co-branded with retailers are financed through a separate securitisation.
KEY RATING DRIVERS
Unchanged Asset Assumptions: ֳ has maintained its asset assumptions, with the steady-state charge-off rate held at 17% and monthly payment rate (MPR) at 11%. We changed these levels earlier this year to reflect (i) NewDay's increasing strategic focus on acquiring and retaining slightly lower risk borrowers; (ii) the strength and stability of portfolio performance metrics during challenging macroeconomic conditions; and (iii) continued refinements to NewDay's automated credit scoring process.
Charge-off and MPR stresses are unchanged and remain at the low end of the criteria range (3.5x and 45% at the 'AAAsf' rating case, respectively). This considers the high absolute level of the steady-state charge-off rate, the low volatility in the historical data and the low payment rates typical of the non-prime credit card sector.
Sound Performance Relative to Steady States: The transaction's recent performance remains below ֳ's steady-state charge-off rate. Over the last year, charge-offs and the MPR have averaged 12.3% and 14.2%, respectively. Performance metrics are expected to fluctuate around our steady states through the economic cycle.
VFN Add Flexibility: The structure includes a separate originator variable funding note (VFN), purchased and held by NewDay Funding Transferor Ltd (the transferor), in addition to series VFN-F1 and VFN-F2 providing the funding flexibility typical and necessary for credit card trusts. It provides credit enhancement to the rated notes, adds protection against dilutions by way of a separate functional transferor interest and meets UK and US risk-retention requirements.
Key Counterparties Unrated: The NewDay group acts in several capacities through its various entities, most prominently as originator, servicer and cash manager. The degree of reliance on the group is mitigated by the transferable operations, agreements with established card service providers, a back-up cash management agreement and a series-specific liquidity reserve. Additionally, a back-up servicer was appointed in October 2024. Upon the occurrence of a servicer termination event, the back-up servicer will replace the existing servicer within 30 days.
RATING SENSITIVITIES
Factors that Could, Individually or Collectively, Lead to Negative Rating Action/Downgrade
Rating sensitivity to increased charge-off rate
Increase steady state by 25% / 50% / 75%:
Series 2024-3 A: 'AA+sf'/ 'AAsf' / 'AA-sf'
Series 2024-3 B: 'AA-sf'/ 'A+sf' / 'Asf'
Series 2024-3 C: 'Asf'/ 'BBB+sf' / 'BBBsf'
Series 2024-3 D: 'BBB-sf'/ 'BB+sf' / 'BB-sf'
Series 2024-3 E: 'B+sf'/ 'Bsf' / N.A.
Series 2024-3 F: 'Bsf'/ N.A. / N.A.
Rating sensitivity to reduced monthly payment rate (MPR)
Reduce steady state by 15% / 25% / 35%:
Series 2024-3 A: 'AA+sf'/ 'AAsf' / 'AA-sf'
Series 2024-3 B: 'AAsf'/ 'A+sf' / 'Asf'
Series 2024-3 C: 'Asf'/ 'A-sf' / 'BBB+sf'
Series 2024-3 D: 'BBBsf'/ 'BBB-sf' / 'BB+sf'
Series 2024-3 E: 'BB-sf'/ 'BB-sf' / 'B+sf'
Series 2024-3 F: 'B+sf'/ 'B+sf' / 'Bsf'
Rating sensitivity to reduced purchase rate
Reduce steady state by 50% / 75% / 100%:
Series 2024-3 D: 'BBBsf'/ 'BBBsf' / 'BBBsf'
Series 2024-3 E: 'BB-sf'/ 'BB-sf' / 'BB-sf'
Series 2024-3 F: 'BB-sf'/ 'B+sf' / 'B+sf'
No rating sensitivities are shown for the class A to C notes, as ֳ already assumes a 100% purchase rate stress in these rating scenarios.
Rating sensitivity to increased charge-off rate and reduced MPR
Increase steady-state charge-offs by 25% / 50% / 75% and reduce steady-state MPR by 15% / 25% / 35%:
Series 2024-3 A: 'AAsf'/ 'Asf' / 'BBB+sf'
Series 2024-3 B: 'A+sf'/ 'BBB+sf' / 'BBB-sf'
Series 2024-3 C: 'BBB+sf'/ 'BBB-sf' / 'BBsf'
Series 2024-3 D: 'BB+sf'/ 'BB-sf' / 'Bsf'
Series 2024-3 E: 'Bsf'/ N.A. / N.A.
Series 2024-3 F: 'Bsf'/ N.A. / N.A.
Factors that Could, Individually or Collectively, Lead to Positive Rating Action/Upgrade
Rating sensitivity to reduced charge-off rate and increased MPR
Reduce steady-state charge-offs by 25% and increase steady-state MPR by 15%:
Series 2024-3 A: 'AAAsf'
Series 2024-3 B: 'AAAsf'
Series 2024-3 C: 'AAAsf'
Series 2024-3 D: 'Asf'
Series 2024-3 E: 'BBBsf'
Series 2024-3 F: 'BBB-sf'
USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10
Form ABS Due Diligence-15E was not provided to, or reviewed by, ֳ in relation to this rating action.
DATA ADEQUACY
NewDay Funding
ֳ has checked the consistency and plausibility of the information it has received about the performance of the asset pool and the transaction. ֳ has not reviewed the results of any third party assessment of the asset portfolio information or conducted a review of origination files as part of its ongoing monitoring.
Prior to the transaction closing, ֳ sought to receive a third party assessment conducted on the asset portfolio information, but none was available for this transaction. The last third party assessment for this master program was received in June 2024.
Prior to the transaction closing, ֳ conducted a review of a small targeted sample of the originator's origination files and found the information contained in the reviewed files to be adequately consistent with the originator's policies and practices and the other information provided to the agency about the asset portfolio.
Overall, and together with any assumptions referred to above, ֳ's assessment of the information relied upon for the agency's rating analysis according to its applicable rating methodologies indicates that it is adequately reliable.
REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF RATING
The principal sources of information used in the analysis are described in the Applicable Criteria.
REPRESENTATIONS, WARRANTIES AND ENFORCEMENT MECHANISMS
A description of the transaction's representations, warranties and enforcement mechanisms (RW&Es) that are disclosed in the offering document and which relate to the underlying asset pool is available by clicking the link to the Appendix. The appendix also contains a comparison of these RW&Es to those ֳ considers typical for the asset class as detailed in the Special Report titled 'Representations, Warranties and Enforcement Mechanisms in Global Structured Finance Transactions'.
ESG Considerations
The highest level of ESG credit relevance is a score of '3', unless otherwise disclosed in this section. A score of '3' means ESG issues are credit-neutral or have only a minimal credit impact on the entity, either due to their nature or the way in which they are being managed by the entity. ֳ's ESG Relevance Scores are not inputs in the rating process; they are an observation on the relevance and materiality of ESG factors in the rating decision. For more information on ֳ's ESG Relevance Scores, visit /topics/esg/products#esg-relevance-scores.
Additional information is available on
PARTICIPATION STATUS
The rated entity (and/or its agents) or, in the case of structured finance, one or more of the transaction parties participated in the rating process except that the following issuer(s), if any, did not participate in the rating process, or provide additional information, beyond the issuer’s available public disclosure.
APPLICABLE CRITERIA
APPLICABLE MODELS
Numbers in parentheses accompanying applicable model(s) contain hyperlinks to criteria providing description of model(s).
- Global Credit Card Cash Flow Model, v1.12.0 (1)
ADDITIONAL DISCLOSURES
ENDORSEMENT STATUS
NewDay Funding | UK Issued, EU Endorsed |