Preliminary Verification Report - In respect of the Transaction "Silver Arrow Athlon NL 2021-1" (Athlon Car Lease Nederland B.V.) - STS ...
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Preliminary Verification Report In respect of the Transaction “Silver Arrow Athlon NL 2021-1” (Athlon Car Lease Nederland B.V.) 10 May 2021
Authorization of SVI as third party
STS Verification International GmbH (“SVI”) has been authorized by the German Federal Financial Supervisory Authority (Bundesanstalt für
Finanzdienstleistungsaufsicht “BaFin”, as the competent authority pursuant to Art 29 of the Securitisation Regulation and § 44 German
Banking Act) to act in all EU countries as third party pursuant to Art 28 of the Securitisation Regulation to verify compliance with the
STS Criteria pursuant to Art 27 (2) of the Securitisation Regulation.
Mandating of SVI and verification steps
On 18 December 2020, SVI has been mandated by the Originator (Athlon Car Lease Nederland B.V.) to verify compliance with the STS
criteria pursuant to Article 28 of the Securitisation Regulation for the securitisation transaction “SILVER ARROW ATHLON NL 2021-1” (the
“Transaction”).
As part of our verification work, we have met with representatives of Athlon Car Lease Nederland B.V., Daimler Mobility AG and Daimler AG
to conduct a virtual due diligence meeting on 17 December 2020. In addition, we have discussed selected aspects of the Transaction with
Athlon Car Lease Nederland B.V., Daimler AG and legal counsel and obtained additional information on the transaction structure, the
underwriting and servicing procedures of Athlon Car Lease Nederland B.V. and the underlying transaction documentation.
For the purposes of our analysis, we have reviewed the following (draft) documents and other information related to the Transaction:
• Preliminary Prospectus
• Dutch Legal Opinion
• Master Hire Purchase Agreement
• RV Guarantee Agreement
• Servicing Agreement
• Account Agreement
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 2 of 30• Due Diligence Presentation by Athlon
• Agreed-upon Procedures Report
• Latest version of the liability cash flow model
• Data Package received by Athlon
• Additional information received by e-mail, such as confirmations, comments, etc.
Verification Methodology
The fulfilment of each verification point in this Preliminary Verification Report provided to the Originator is evaluated based on the three
fulfilment values (traffic light status):
Criterion is fully met
Criterion is mostly met, but with comments or requests for missing information
Criterion not (yet) met based on available information
The verification process is based on the SVI verification manual (“Verification Manual”), defined terms of the Verification Manual shall also
apply to this report. It describes the verification process and the individual inspections in detail. The Verification Manual is applicable to all
parties involved in the verification process and its application ensures an objective and uniform verification of transactions to be verified.
Based on the Verification Manual, SVI has derived the Transaction Verification Catalogue for this Transaction as described under Verification
Method in this report. A full description of the methodology used by SVI for the Verification can be found in the Verification Manual on our
website: www.svi-gmbh.com.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 3 of 30Disclaimer of SVI
SVI grants a registered verification label “verified – STS VERIFICATION INTERNATIONAL” if a securitisation complies with the requirements
for simple, transparent and standardised securitisation as set out in Articles 19 to 22 of the Securitisation Regulation ("STS Requirements").
The aim of the Securitisation Regulation is to restart high-quality securitisation markets, and the intention of implementing a framework for
simple, transparent and standardised transactions with corresponding STS criteria shall contribute to this. However, it should be noted that
the STS verification performed by SVI does not affect the liability of an originator or special purpose vehicle in respect of their legal
obligations under the Securitisation Regulation. Furthermore, the use of verification services from SVI shall not affect the obligations imposed
on institutional investors as set out in Article 5 of the Securitisation Regulation. Notwithstanding confirmation by SVI, which verifies
compliance of a securitisation with the STS Requirements, such verification by SVI does not ensure the compliance of a securitisation with
the general requirements of the Securitisation Regulation.
SVI has carried out no other investigations or surveys in respect of the issuer or the notes concerned other than as set out in this Preliminary
Verification Report and disclaims any responsibility for monitoring the issuer’s continuing compliance with these standards or any other
aspect of the issuer’s activities or operations. Furthermore, SVI has not provided any form of advisory, audit or equivalent service to the
Originator, Issuer or Sponsor.
Investors should therefore not evaluate their investment in notes based on this Preliminary Verification Report.
SVI assumes due performance of the contractual obligation thereunder by each of the parties and the representations made and warranties
given in each case by any persons or parties to SVI or in any of the documents are true, not misleading and complete.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 4 of 30LIST OF ABBREVIATIONS/DEFINITIONS
Note: For any other term used in this Preliminary Verification Report in capital spelling, please refer to the defined terms in section 24
“GLOSSARY OF CERTAIN DEFINED TERMS” in the Preliminary Prospectus.
Athlon Athlon Car Lease Nederland B.V.
AuP Agreed-upon Procedures
BaFin Bundesanstalt für Finanzdienstleistungsaufsicht (German Federal Financial Supervisory Authority)
BOVAG Bond Van Automobielhandelaren en Garagehouders (Dutch Association of Car Dealers)
CF-Model Cash Flow-Model
Closing Date 16 June 2021
Due Diligence Presentation Due Diligence Presentation dated December 2020 and prepared by Athlon
EBA European Banking Authority
EBA Guidelines Final Report on Guidelines on the STS criteria for non-ABCP securitisation, as published by EBA on 12 December 2018
ESMA European Securities and Markets Authority
FOCWA Nederlandse Vereniging van Ondernemers in het Carrosseriebedrijf (Dutch Association of Enterprises in car body work)
Issuer Silver Arrow Athlon NL 2021-1
LO Dutch Legal Opinion
MHPA Master Hire Purchase Agreement
Originator Athlon Car Lease Nederland B.V.
Preliminary Prospectus Preliminary Prospectus dated [5] May 2021
Preliminary Verification Report Preliminary Verification Report prepared by SVI in respect of the Transaction
Securitisation Regulation Regulation (EU) 2017/2402 of the European Parliament and of the Council of 12 December 2017 laying down a general
framework for securitisation and creating a specific framework for simple, transparent and standardised securitisation, and
amending Directives 2009/65/EC, 2009/138/EC and 2011/61/EU and Regulations (EC) No 1060/2009 and (EU) No 648/2012
Seller Athlon Car Lease Nederland B.V.
Servicer Athlon Car Lease Nederland B.V.
SPV Special Purpose Vehicle or Issuer
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 5 of 30STS Requirements The requirements for simple, transparent and standardised securitisation in respect of a non-ABCP transaction as set out in
Articles 19 to 22 of the Securitisation Regulation
Transaction The securitisation of auto lease receivables involving Silver Arrow Athlon NL 2021-1 as Issuer
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 6 of 30# Criterion Article 20 (1) Verification Report
1 Assignment or transfer of Verification Method: Legal (Legal opinion, Prospectus) / Due Diligence
ownership of the risk positions
The Transaction involves from time to time a transfer of Leased Vehicles together with the associated Lease Receivables from
takes place by means of a true
Athlon to the Issuer which meet the Eligibility Criteria and the Replenishment Criteria. The transfer of the Leased Vehicles and
sale and is legally enforceable.
Lease Receivables is effected by way of a Hire Purchase Agreement between Athlon and the SPV resulting in a conditional transfer
of title of the Leased Vehicles (subject to payment of the full hire purchase price by way of set-off or actual payment). Under a
hire purchase contract, the parties agree that the purchase price for the relevant asset is paid in regular instalments and that
unconditional legal ownership to the asset does not transfer at the time of delivery of the asset to the hire purchaser, but only
upon fulfilment of the condition precedent that the purchase price shall have been paid in full (i.e. upon payment of the final
instalment). Upon payment in full, the Issuer will automatically by operation of law become the unconditional legal owner of such
Purchased Vehicle, even in case of a Seller insolvency. The transfer of the Leased Vehicles and Lease Receivables is considered to
result from the Hire Purchase Agreement and is complemented by an assignment of the Lease Receivables from Athlon to the
Issuer. To perfect the assignment of the Lease Receivables, a notification will be sent to the relevant Lessee and each deed of
assignment will be registered with the Dutch tax authorities (Belastingdienst) within two (2) Business Days after the relevant
Purchase Date. To the extent obligations under the Lease Agreements are not automatically transferred by operation of law upon
the transfer to the Issuer of full title to the relevant Purchased Vehicle, they are separately assumed by the Issuer.
The Legal Opinion confirms that upon due execution of a Combined Transfer Deed (subject to registration or signing before a
notary) (i) the valid sale by the Seller and purchase of the Leased Vehicles by the Issuer by way of hire purchase of the Leased
Vehicles and (ii) the valid assignment of the Lease Receivables by the Seller to the Issuer, all subject to customary qualifications,
in particular relating to (i) the location of the Leased Vehicles outside the Netherlands at the time of transfer, (ii) regarding the
assignment of receivables not yet due as future receivables and (iii) retention of title issues in connection with the application of
BOVAG and FOCWA general conditions.
The LO confirms that the lease contracts do not contain transfer restrictions in respect of the Lease Receivables.
The Master Hire Purchase Agreement contains representations and warranties by the Seller as of the relevant Purchase Date that
(i) the Leased Vehicles, the associated Lease Agreements and Lease Receivables are true, correct and not misleading in any
material respect; (ii) the Seller has full right and title to the Leased Asset, free and clear of any Adverse Claim, and has power to
transfer or encumber (is beschikkingsbevoegd) the Leased Asset; (iii) the Lease Receivables are, to the best of the Seller’s
knowledge, not encumbered; and (iv) the Lease Agreement has been entered into in accordance with all applicable legal
requirements.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 7 of 30# Criterion Article 20 (1) Verification Report
2 Requirements for the external Verification Method: Legal (Legal opinion) / Due Diligence
legal opinion
The LO is provided by Loyens & Loeff, which is a reputable Dutch law firm with expertise in the area of securitisation.
The LO is made available to the third-party verification agent and competent supervisory authorities
# Criterion Article 20 (2) Verification Report
3 Specification of increased claw- Verification Method: Legal (Legal opinion)
back risks: Are there any
The LO sets out the relevant Dutch law claw back provisions and concludes that the Dutch Bankruptcy Act (Faillissementswet)
provisions in the respective
does not contain severe clawback provisions as referred to in article 20(1) and (2) of the Securitisation Regulation and such
national insolvency law, which
clawback provisions are therefore not applicable to this securitisation.
could render the transfer
voidable?
# Criterion Article 20 (3) Verification Report
4 Specification of non-increased Verification Method: Legal (Legal opinion)
claw-back risks: National
Applicable Dutch insolvency laws are considered not to represent any severe claw-back risks (see above under #3).
insolvency laws are not severe,
if they allow for the invalidation
of the sale of the underlying
exposures in the event of
fraudulent transfers, unfair
prejudice to creditors or
favouring particular creditors
over others.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 8 of 30# Criterion Article 20 (4) Verification Report
5 If the sale and transfer is not Verification Method: Legal (Legal opinion, Master Hire Purchase Agreement)
taking place directly between
Under the transaction structure used by Silver Arrow Athlon NL 2021-1 B.V., the sale and transfer take place directly between the
the seller and the SPV but
Seller (who is the original lender) and the SPV acting as Issuer, i.e. without any intermediate sale taking place.
intermediate sales take place,
is the true sale still fulfilled?
# Criterion Article 20 (5) Verification Report
6 If the transfer of receivables Verification Method: Legal (Legal opinion, Master Hire Purchase Agreement)
and the perfection take place
The transfer of the Initial Leased Vehicles together with the associated Lease Receivables will occur on the Closing Date of the
at a later stage, are the trigger
Transaction (scheduled for 16June 2021) and during the Revolving Period (please also refer to #8) the transfer of Additional
events in relation to the seller’s
Leased Vehicles will occur on each Additional Purchase Date (see section 8.3 “Master Hire Purchase Agreement” of the Preliminary
credit quality standing
Prospectus). As described, there are no circumstances in which the transfer of the underlying exposures will be performed by
sufficiently defined?
means of an assignment and perfected at a later stage than at the Closing Date or each Additional Purchase Date.
# Criterion Article 20 (6) Verification Report
7 Representations and Verification Method: Legal (Master Hire Purchase Agreement)
warranties of the seller
The Seller (who is the original lender) warrants that the Lease Agreements are legally valid, binding and enforceable contractual
regarding to the legal condition
obligations of the relevant Lessee and that, to the best of its knowledge, the Purchased Vehicles together with the associated
of the underlying exposures
Lease Receivables are not encumbered or otherwise in a condition that can be foreseen to adversely affect the enforceability of
the true sale or assignment or transfer with the same legal effect, see clause 9.1 “Representations and warranties relating to the
Leased Assets”, items (a), (b), (c), (h) and (m) of the MHPA, in combination with Schedule 1 “Eligibility Criteria” of the MHPA.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 9 of 30# Criterion Article 20 (7) Verification Report
8 Predetermined, clear and Verification Method: Legal (Master Hire Purchase Agreement)
documented selection criteria
The transfer of the underlying exposures from the Seller to the SPV are selected according to predetermined, clear and
('eligibility criteria') (I/II)
documented eligibility criteria, see Schedule 1 “Eligibility Criteria” of the MHPA.
A Revolving Period is provided for in the transaction structure. On each Additional Purchase Date during the Revolving Period, the
Issuer is, pursuant to the terms of the MHPA and subject to certain requirements set out therein, obliged to purchase Additional
Lease Vehicles together with the associated Lease Receivables offered by the Seller. On any relevant Purchase Date, any Leased
Assets offered for purchase on such Purchase Date must meet the Eligibility Criteria specified in Schedule 1 “Eligibility Criteria” of
the MHPA. As a consequence, consistent Eligibility Criteria apply on the Initial Purchase Date and any Additional Purchase Date
thereafter which falls into the Revolving Period.
# Criterion Article 20 (7) Verification Report
9 Predetermined, clear and Verification Method: Data (AuP Report)
documented selection criteria
The asset audit, whereby the audit company performs certain Agreed-upon Procedures with respect to the compliance of the
('eligibility criteria') (II / II)
underlying exposures in a randomly selected sample, covers the key eligibility criteria specified for the Transaction. Please also
refer to #40 for a summary of the scope of the asset audit.
# Criterion Article 20 (7) Verification Report
10 No active portfolio management Verification Method: Legal (Transaction Documents)
The underlying exposures in the provisional and the final pool are selected based on a well-established, random selection process.
In case a Leased Receivable did not fulfil the Eligibility Criteria on the relevant Cut-Off Date or on the Additional Purchase Date,
the Seller will be obliged to remedy such breach, and if not capable of remedy, to repurchase such Lease Receivable at the
relevant Purchase Price on the immediately following Payment Date. There will, however, be no substitution of the ineligible
receivable with a new receivable. Please refer to 8.3 “Master Hire Purchase Agreement”, item “Breach of Asset Warranty or
Corporate Warranty” of the Preliminary Prospectus.
The Transaction structure foresees a Clean-Up Call Option that can be exercised by the Seller on any Payment Date on which (i)
the Aggregate Discounted Balance is less than 10% of the Aggregate Discounted Balance as of the Initial Cut-Off Date or (ii) the
Class A Notes including any interest accrued but unpaid are redeemed in full, section 6.5 “Redemption following Seller Clean-Up
Call” of the Preliminary Prospectus.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 10 of 30Upon the occurrence of a Lease Termination Date, the Seller as Call Option Buyer may exercise a Repurchase Option at the
Option Exercise Price. If the Seller exercises a Repurchase Option, the relevant Purchased Vehicle will be retransferred to the
Seller together with the associated Lease Receivables, see 8.3 “Master Hire Purchase Agreement”, item “Exercise of Repurchase
Option” of the Preliminary Prospectus.
All of the above-described instances that allow for a repurchase of underlying exposures fall under the techniques of portfolio
management that should not be considered active portfolio management. Generally, the above described repurchase mechanism
used in the Transaction (a) does not make the performance of the Transaction dependent both on the performance of the
underlying exposures and on the performance of the portfolio management, and (b) is not performed for speculative purposes
aiming to achieve better performance, increased yield, overall financial returns or other purely financial or economic benefit.
As a result of the above, the criterion “no active portfolio management” is fulfilled.
# Criterion Article 20 (8) Verification Report
11 Securitisation of a Verification Method: Legal (Transaction documents)
homogeneous portfolio in
The underlying exposures fall into the asset type according to Art. 1 (a) (v) of the Commission Delegated Regulation (EU)
terms of asset classes (I / III)
2019/1851 on the homogeneity (i.e. auto loans and leases).
The Seller has chosen the homogeneity factor according to Art. 2 (4.) (b) of the Commission Delegated Regulation (EU)
2019/1851 on the homogeneity of the underlying exposures, i.e. jurisdiction, whereby the pool, as of the Initial and Additional
Purchase Date on which the offer relating to the respective Leased Vehicles together with the associated Lease Receivables is
made, shall consist of underlying exposures relating to Lessees with residence in one jurisdiction (Netherland) only, see Schedule
1 “Eligibility Criteria”, item (2.) of the MHPA and section 9.5 “Pool Size and Characteristics” of the Preliminary Prospectus.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 11 of 30# Criterion Article 20 (8) Verification Report
12 Securitisation of a homogeneous Verification Method: Due Diligence (Underwriting and Servicing Policy)
portfolio in terms of asset
The underlying exposures have been originated in accordance with consistent underwriting standards, as shown in the Due
classes (II / III)
Diligence Presentation and further described in #17. No distinction is made between securitised and non-securitised receivables.
The processes assure that only Lessees located in the Netherlands are originated according to the underwriting policy.
The same applies to the servicing policy, with the underlying exposures being serviced using consistent standards and no
distinction being made between securitised and non-securitised receivables. Please also refer to #35 and #36 for more details on
the servicing procedures.
# Criterion Article 20 (8) Verification Report
13 Securitisation of a homogeneous Verification Method: Data (AuP Report)
portfolio in terms of asset
The Eligibility Criteria restrict the underlying exposures to Lease Receivables originated under a Lease Agreement, thereby
classes (III / III)
assuring that the relevant Lessee of the Leased Vehicle is a legal entity or private individual conducting an enterprise (werkzaam
in de uitoefening van een beroep of bedrijf), located in the Netherlands. This specific feature has not been verified through the
Eligibility Criteria Verification (see #40). Given that the homogeneity of the portfolio can be derived from the legal documentation
and the due diligence (see ##11 and 12 above), this is, however, not detrimental.
# Criterion Article 20 (8) Verification Report
14 The underlying exposures Verification Method: Legal (Legal opinion) / Due Diligence
contain obligations that are
Section 8.3 “Master Hire Purchase Agreement”, item “Representations and warranties” of the Preliminary Prospectus contain
contractually binding and
warranties by the Seller as to the legally valid, binding and enforceable nature of the underlying exposures, i.e. the Lease
enforceable
Agreements under which the relevant Lease Receivables arises. Please also refer to #1.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 12 of 30# Criterion Article 20 (8) Verification Report
15 The underlying exposures have Verification Method: Legal (Legal opinion, Transaction documents) / Due Diligence / Data (AuP Report)
defined periodic payment
The underlying exposures for the transaction represent standard lease agreements originated by Athlon Car Lease Nederland B.V.
streams and do not include
in respect of large corporates, small- and medium-sized enterprises and individual entrepreneurs. The Seller provides multiple
transferable securities other
types of car leasing and mobility solutions. For the purposes of the transaction, two contract types form part of the securitised
than unlisted corporate bonds
portfolio:
1. Lease type “closed-end lease”, the Lessee is not liable for any negative fluctuations in the value of the vehicle.
2. Lease type “open-end lease”, a shortfall or surplus relative to the agreed residual value may either be shared between
the lessor and the Lessee or the Lessee will fully benefit from a surplus while the lessor will fully bear a shortfall.
Apart from these variations, the two lease types do not differ structurally in terms of payment streams, see the respective section
9.2 “Contract types” of the Preliminary Prospectus. Payments by the Lessees under the Purchased Vehicles are due on a monthly
basis.
As shown in the Due Diligence Presentation and described in the Preliminary Prospectus, the underlying exposures have defined
periodic payment streams relating to, interest, arrears, fees or costs under any relevant operational car lease contract relating to
any of the foregoing. The Receivables derive from lease contracts which provide for regular monthly lease instalments resulting in
regular monthly instalments at the end of the contract term. Please also refer to sections 9.3 “Lease instalment” of the
Preliminary Prospectus.
The Eligibility Criteria restrict the underlying exposures to Lease Receivables originated under a Lease Agreement. The compliance
of the provisional pool with the eligibility criteria has been verified through the Eligibility Criteria Verification (see #40).
# Criterion Article 20 (9) Verification Report
16 Are there any securitisation Verification Method: Legal (Transaction documents) / Due Diligence
positions in the portfolio?
The Eligibility Criteria, representations and warranties restrict the underlying exposures to Lease Receivables originated under a
Lease Agreement, thereby assuring that no securitisation position may become part of the portfolio.
As demonstrated during the Due Diligence, the origination and/or resale of securitisation positions is not part of the business
model of the Seller and not permitted under the Seller’s underwriting policy.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 13 of 30# Criterion Article 20 (10) Verification Report
17 Origination of underlying Verification Method: Legal (Transaction documents) / Due Diligence (Underwriting and Servicing Policy)
exposures in the ordinary
Athlon Car Lease Nederland B.V. is a wholly owned subsidiary of Athlon Car Lease International B.V. and indirectly a 100 per cent.
course of business of the
subsidiary of Daimler AG. The Seller provides leasing services primarily to corporate customers. The car lease activities are
originator or the original lender
focused on operational leasing, fleet management and rental services. Athlon has originated and serviced auto-leases for more
than five (5) years, being exposures similar to the hire purchased Leased Vehicles and the associated Lease Receivables.
The Seller’s business procedures assure that securitised exposures have been originated in the ordinary course of business and in
accordance with uniform standards. Deviations from the underwriting policy are only permissible in well-defined and documented
instances. Please refer to clause 9.1 “Representations and warranties relating to the Leased Assets”, item (m) of the MHPA and
section 9.5 “Pool Size and Characteristics” of the Preliminary Prospectus.
As discussed in the Due Diligence, the well-developed and highly professional organisation of the Seller’s business procedures is in
line with the volume and quantity of business transactions.
The underlying exposures are similar to the non-securitised loan contracts in the asset type “auto loans and leases” (see definition
of “similar exposures” in the EBA Guidelines) due to the strictly random selection process.
A Revolving Period is provided for in the transaction structure. The Additional Leased Vehicle together with the Purchased Vehicles
and the associated Lease Receivables shall comply with the Replenishment Criteria and the Eligibility Criteria as well. The Seller in
its capacity as Servicer covenants in the Servicing Agreement not to amend, vary or supplement in any material way any terms of
the Lease Agreements other than in accordance with the Credit and Collection Policy or where it would not have a Material
Adverse Effect on the Issuer. Please refer to subsection 1.2.2 “Economic and other risks related to the Leased Vehicles, Lease
Agreements and Lease Receivables”, item “Credit and Collection Policy” of the Preliminary Prospectus.
# Criterion Article 20 (10) Verification Report
18 Underwriting standards for Verification Method: Due Diligence
securitised exposures are no
As presented and discussed in the Due Diligence, no distinction is made between securitised and non-securitised exposures in any
less stringent than those applied
respect, be it applicable regulatory standards, competence grid and involvement of decision-makers, distribution channels,
to non-securitised exposures
product types and product characteristics, annual agreements on (sales) objectives, sales management measures and bonus
systems, lending standards, approval processes and incentive measures, credit processing, dunning procedures, debt collection,
realisation of collateral (including the policies or procedures relating to the residual value determination and realisation), customer
service, outsourcing of sales, underwriting and servicing activities or areas of risk controlling, accounting and reporting (except for
the required reporting of ABS transactions).
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 14 of 30Employees of the Originator involved in the underwriting do not know whether a risk position currently being processed for
application will be securitised at a later stage or not.
The Seller in its capacity as Servicer does have at least 5 years of experience in origination and underwriting of exposures similar
to those securitised, see subsection 13.1.1 “Description of the Seller” of the Preliminary Prospectus.
# Criterion Article 20 (10) Verification Report
19 Where the underlying exposures Verification Method: Due Diligence
are residential mortgage
The Eligibility Criteria restrict the underlying exposures to Leased Assets (means Leased Vehicles and the associated Lease
loans, does the portfolio include
Agreements and Lease Receivables) – therefore, residential mortgage loans do not form part of the portfolio, please refer to
loans that have been self-
Schedule 1 “Eligibility Criteria” of the MHPA.
certified by the loan
applicants?
# Criterion Article 20 (10) Verification Report
20 Assessment of the Verification Method: Regulatory / Legal / Due Diligence / Data
borrower’s creditworthiness
The Seller is a private company with limited liability (besloten vennootschap met beperkte aansprakelijkheid) under Dutch law
performed in accordance
and provides leasing services. As such, the services and activities of the Seller are not governed by Directives 2008/48/EC
with certain EU Directives on
(regarding credit agreements for consumers) and 2014/17/EU (regarding credit agreements for consumers relating to residential
credit agreements for
immovable property). Notwithstanding this, the Seller performs the „Assessment of the borrower’s creditworthiness” with respect
consumers or on credit
to lease agreements on the basis of sufficient information, where appropriate obtained from the Lessee and, where necessary, on
agreements for consumers
the basis of a consultation of the relevant database, which is in accordance with Article 8 of Directive 2008/48/EC.
relating to residential
immovable property or, if
applicable, the analogous
provisions of a third country
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 15 of 30# Criterion Article 20 (10) Verification Report
21 Originator's experience (as Verification Method: Regulatory (suitable proof incl. Website) / Due Diligence
an entity or through
As an institution, the Originator does have at least 5 years of experience in origination and underwriting of exposures similar to
management and senior staff) in
those securitised, see subsection 13.1.1 “Description of the Seller” of the Preliminary Prospectus.
origination of similar risk
positions As demonstrated in the Due Diligence, the management has a long-term experience in origination and underwriting of Lease
Agreements and related Lease Receivables and the determination of the residual value of the Leased Vehicles.
# Criterion Article 20 (11) Verification Report
22 The underlying exposures are Verification Method: Legal (Transaction documents)
transferred without undue
The dates of the provisional and final pool cuts are 31 March 2021 and 31 May 2021, respectively. The Lease Agreements are
delay after selection
transferred from the Seller to Issuer at closing (scheduled for 16 June 2021) and later on the relevant Purchase Date, i.e. without
undue delay after selection. This occurs through provision by the Seller of a Combined Transfer Deed constituting an irrevocable
offer by the Seller to sell Leased Vehicles, within two (2) Business Days following the relevant Purchase Date.
# Criterion Article 20 (11) Verification Report
23 The underlying exposures do not Verification Method: Regulatory / Legal (Transaction documents) / Due Diligence
include any defaulted
The Originator is not an institution subject to Regulation (EU) 575/2013. As presented in the Due Diligence and confirmed in the
exposures or to
Preliminary Prospectus the Leased Vehicles together with the associated Lease Receivables are transferred to the Issuer after
debtors/guarantors with
selection without undue delay and do not include, at the time of selection and to the best of the Originator´s knowledge,
impaired creditworthiness
exposures in default within the meaning of Article 178 (1) of Regulation (EU) No 575/2013 or exposures to a credit-impaired
Lessee (see as confirmed in section 7.4 “Compliance with STS Requirements” of the Preliminary Prospectus).
Accordingly, the Seller represents and warrants that, to the Seller’s best knowledge, the underlying exposures will not include
Lease Receivables relating to a credit-impaired Lessee, who (i) has been declared insolvent or had a court grant his creditors a
final non-appealable right of enforcement or material damages as a result of a missed payment within three (3) years prior to the
date of origination or has undergone a debt-restructuring process with regard to his non-performing exposures within three (3)
years prior to the Purchase Date on which the Leased Assets related to such Lessee were transferred; (ii) was, at the time of
origination, where applicable, on a public credit registry of persons with adverse credit history or, where there is no such public
credit registry, another credit registry in the Netherlands that is available to the Seller; or (iii) has a credit assessment or a credit
score indicating that the risk of contractually agreed payments not being made is significantly higher than for comparable
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 16 of 30exposures held by the Seller which are not securitised. Please refer to clause 9.1 “Representations and warranties relating to the
Leased Assets”, item (g) of the MHPA.
The Originator represents, with regards to the question which sources of information it has used to identify defaulted exposures
and to determine if an Lessee is credit-impaired, that it has obtained information (1) from the Lessee of the Lease Receivables on
origination of the exposures, (2) in the course of Athlon Car Lease Nederland B.V.’s servicing of the Lease Receivables or of
Athlon Car Lease Nederland B.V’s risk management procedures, or (3) from a third party (including publicly available
information).
The Originator has IT systems in place to ensure that defaulted exposures or exposures to debtors/guarantors with impaired
creditworthiness are excluded from the provisional or final pool cut.
# Criterion Article 20 (11) Verification Report
24 The risk positions do not have a Verification Method: Due Diligence
credit assessment or a credit
The most relevant factors determining the expected performance of the underlying exposures in the securitised portfolio are the
score that allows a significantly
profiles of the corporate customers, credit agencies’ information and financial information as well as past payment behaviour. All
higher default risk to be expec-
of these factors have an impact on the credit score. Furthermore, the expected performance of the underlying exposures depends
ted than for non-securitised risk
on the factors (but not limited to) make, model, mileage, engine, powertrain as well as general market conditions.
positions
These factors are the same for securitised and non-securitised exposures due to the strictly random selection process.
On this basis, it can be reasonably assumed that – in comparison to non-securitised exposures – no worse performance should
occur for securitised exposures for the term of the Transaction.
The requirement that the underlying exposures do not have a “credit assessment or a credit score indicating that the risk of
contractually agreed payments not being made is significantly higher than for comparable receivables held by the Originator
which are not securitised” is considered to be met as the underlying exposures do not include (i) exposures that are classified as
doubtful, impaired, non-performing or similar, or (ii) exposures whose credit quality (based on credit ratings or other credit
quality thresholds) significantly differs from the quality of other exposures ordinarily originated by the Seller.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 17 of 30# Criterion Article 20 (12) Verification Report
25 At the time of the transfer, the Verification Method: Legal (Transaction documents)
debtor has paid at least 1
The Originator warrants that on the relevant Cut-Off Date at least one Lease Instalment of the relevant associated Lease
instalment
Receivable has been paid by the relevant Lessee under the associated Lease Agreement, see Schedule 1 “Eligibility Criteria”, item
(15.) of the MHPA.
# Criterion Article 20 (13) Verification Report
26 The repayment of the securi- Verification Method: Legal (Transaction documents) / Due Diligence / Data
tisation position should not be
The underlying exposures for the Transaction consist of (i) Lease Receivables (i.e. payment claims in respect of Lease Instalments
predominantly dependent on
arising from the relevant Lease Agreements) payable by the Lessees and (ii) Leased Vehicles and the resulting payments by the
the sale of assets securing the
Seller as the Call Option Buyer).
underlying exposures
Regarding the Lease Receivables, the repayment comes from a granular portfolio of Lessee with a steady cash flow of monthly or
annual instalments with no material reliance on sale of assets.
Regarding the Leased Vehicles, every car returned from a Lessee is subject to the Repurchase Option of the Seller to repurchase
the vehicle from the Issuer. In accordance with the Annex 1 of the combined transfer deed, the Seller may exercise its
Repurchase Option pursuant to clause 11.2 “Exercise of Repurchase Option” of the MHPA in respect of all Purchased Vehicles. In
case the Seller acting as Call Option Buyer elects not to exercise its Repurchase Option, the Servicer will undertake to use its best
efforts to sell, on behalf of and for the account of the Issuer, the Purchased Vehicles. The Issuer is entitled to receive the claim
under the residual value guarantee to cover any RV Shortfall, see section 8.6 “RV Guarantee Agreement” of the Preliminary
Prospectus. Provided that the Issuer received the RV Shortfall Amount from the Seller as RV Guarantor and a Lease Agreement
Early Termination Amount due to a Lease Agreement Early Termination, the Issuer is obliged to pay to the Seller up to an amount
equal to such RV Shortfall Amount after the relevant Lease Early Termination Date.
As a result, the primary source of repayment for the Vehicles Realisation Proceeds relates to the Seller, and secondly (in case of a
default of the Seller) on the sale of assets, hence no predominant dependence on the sale of assets exists.
Furthermore, the described Repurchase Option of the Seller to repurchase the vehicle from the Issuer and combined with the RV
guarantee in case of non-exercise of the Repurchase Option (which fulfils the conditions referred to in the EBA Guidelines, #50,
i.e. (i) is not insolvent, and (ii) there is no reason to believe that it would not be able to meet its obligations under the
Repurchase Option) ensures that the repayment of the securitisation position does not predominantly depend on the sale of
assets (i.e. vehicles) securing the underlying exposures.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 18 of 30Hence the exemption referred to in the second subparagraph of Article 20 (13) of the Securitisation Regulation with regards to the
repayment of holders of securitisation positions whose underlying exposures are secured by assets the value of which is
guaranteed or fully mitigated by a repurchase obligation of either the assets securing the underlying exposures or of the
underlying exposures themselves by another third party or parties applies and therefore no predominant dependence on the sale
of assets exists.
# Criterion Article 21 (1) Verification Report
27 Risk retention (Art. 6.1 of the Verification Method: Legal (Transaction documents) / Due Diligence
Securitisation Regulation),
Holder of risk retention: Athlon Car Lease Nederland B.V. as the Seller, see section 3.5 “Compliance with the Securitisation
usually by the Originator
Regulation” of the Preliminary Prospectus.
Type of risk retention: in accordance with Article 6(3)(d) of Securitisation Regulation, see section 3.5 “Compliance with the
Securitisation Regulation” of the Preliminary Prospectus. The Seller will for the life of the Transaction retain a material net
economic interest of not less than 5% in relation to the Transaction. As of the Closing Date, such interest will be retained through
the holding of the Class B Notes.
The monthly investor reports will also set out monthly confirmation regarding the continued holding of the risk retention by the
Seller. Please refer to section 3.5 “Compliance with the Securitisation Regulation” of the Preliminary Prospectus.
The legal obligation of the Seller to hold the risk retention during the lifetime of the transaction is entered into according to
section 3.5 “Compliance with the Securitisation Regulation” of the Preliminary Prospectus.
# Criterion Article 21 (2) Verification Report
28 Appropriate hedging of Verification Method: Due Diligence
interest rate and currency risks,
Since the Lease Receivables are fixed rate and the Class A Notes are floating rate, interest rate risks arise from such mismatch.
no derivatives as underlying risk
Both assets and liabilities of the Issuer are EUR denominated hence no currency risk occurs.
positions (I / II)
The Lease Receivables and Class B Notes will bear interest at fixed rates while the Class A Notes will bear interest at floating rate
based on 1-M-EURIBOR plus a margin. Interest rate risks for the Class A Notes are hedged appropriately with a fixed floating
interest rate swap where the total notional amount of the swap is always equal to the Principal Amount Outstanding of the Class A
Notes. The floating leg of the swap agreement contains no floor for the 1-M-EURIBOR while the Interest Rates of the Class A
Notes is floored at zero. Any potential remaining mismatches arising from this are taken into account by the rating agencies and
are mitigated in particular by the General Reserve Advance and Class B as part of the credit enhancement.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 19 of 30No further risks in addition to interest rate risks are hedged under the interest rate hedge agreement.
# Criterion Article 21 (2) Verification Report
29 Appropriate hedging of interest Verification Method: Legal (Transaction documents)
rate and currency risks, no
The legal instrument used by the Issuer to hedge interest rate risks is the agreed Swap Agreement for the Class A Notes
derivatives as underlying risk
(“DESCRIPTION OF CERTAIN TRANSACTION DOCUMENTS”, subsection “Swap Agreement” of the Preliminary Prospectus).
positions (II / II)
The agreement considers any potential asset liability mismatch by referencing to the Principal Amount Outstanding of the Class A
Notes, and the agreement is based on the 2002 ISDA Master Agreement as established market standard, see section “8
DESCRIPTION OF CERTAIN TRANSACTION DOCUMENTS”, subsection “SWAP AGREEMENT” as well as the definition of “Swap
Agreement” in section 24.2 “Definitions” of the Preliminary Prospectus.
The requirements for eligible swap counterparties are market standard in international finance, see section 8. “DESCRIPTION OF
CERTAIN TRANSACTION DOCUMENTS”, subsection “Swap Agreement” of the Preliminary Prospectus.
# Criterion Article 21 (3) Verification Report
30 Generally used reference rates Verification Method: Legal (Transaction documents)
for interest payments
No reference rates apply to the Lease Receivables and Class B Notes which bear fixed interest rates
The Class A Notes will bear interest at floating rate based on 1-M-EURIBOR, constituting a market standard reference rate. Please
refer to the definition of “Class A Notes Interest Rate” in the section 24 “GLOSSARY OF CERTAIN DEFINED TERMS”, subsection
24.2 “Definitions” of the Preliminary Prospectus.
No reference rates apply for the interest on the cash accounts.
Currency hedges are not provided for in the transaction structure.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 20 of 30# Criterion Article 21 (4) Verification Report
31 Requirements in the event of Verification Method: Legal (Transaction documents)
an enforcement or delivery of
After the occurrence of an Issuer Events of Default, the priority of payment will change to the Accelerated Amortisation Period
an acceleration notice
Priority of Payments, see section 6.7 “Priority of Payments”, item “Accelerated Amortisation Period Priority of Payments” of the
Preliminary Prospectus. This requires:
(a) No cash will be retained with the Issuer.
(b) The principal receipts from the underlying exposures will be used for the fully sequential amortisation of the securitisation
positions as determined by the seniority of the securitisation position.
(c) The interest and principal payments are first made for the Class A Notes and then interest and principal payments are
made for the subsequent Notes, hence repayments are not reversed with regard to their seniority.
(d) No automatic liquidation or sale of risk positions or assets is provided for.
# Criterion Article 21 (5) Verification Report
32 Sequential repayment as fall- Verification Method: Legal (Transaction documents)
back in the event of a deterio-
The Transaction has a strictly sequential priority of payment.
ration in portfolio quality for
Transactions that feature a non-
sequential priority of
payments
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 21 of 30# Criterion Article 21 (6) Verification Report
33 Early amortisation provisions or Verification Method: Legal (Transaction documents)
triggers for termination of the
General: The Issuer will only be allowed to purchase Additional Leased Vehicles together with the associated Lease Receivables
revolving phase to include at
until a Revolving Period Termination Event (see respective definition in section 24.2 “Definitions” of the Preliminary Prospectus)
least the following:
has occurred. Thus, the Revolving Period will end upon the earlier of (i) the Payment Date falling in 26 [July] 2022 and (ii) the
date on which a Revolving Period Termination Event occurs. The following events trigger a Revolving Period Termination Event:
a) deterioration in the A deterioration in the credit quality of the Receivables to or below a predetermined threshold measured by the Default Ratio (see
credit quality of the item b) and the Delinquency Ratio (see item c) of the definition of “Revolving Period Termination Event” in section 24 “GLOSSARY
underlying exposures OF CERTAIN DEFINED TERMS”, subsection 24.2 “Definitions” of the Preliminary Prospectus).
below a predefined
threshold
b) insolvency-related The occurrence of an insolvency-related event with regard to the Servicer or Seller (as set out in items (a) and (f) of the definition
events in relation to the of “Revolving Period Termination Event” in section 24 “GLOSSARY OF CERTAIN DEFINED TERMS”, subsection 24.2 “Definitions” of
Originator or the the Preliminary Prospectus)
Servicer
c) decline in value of the The Aggregate Discounted Balance plus the amount standing to the credit of the Replenishment Ledger plus the amount standing
underlying exposures to the credit of the General Reserve Account is on any Payment Date below a predetermined threshold, lower than the sum of (i)
below a predefined the Principal Amount Outstanding of the Class A Notes and Class B Notes and (ii) the principal amount outstanding of the
threshold Subordinated Increase Advances (if any), (as set out in item (e) of the definition of “Revolving Period Termination Event” in
section 24 “GLOSSARY OF CERTAIN DEFINED TERMS”, subsection 24.2 “Definitions” of the Preliminary Prospectus)
d) failure to generate A failure to generate sufficient new underlying exposures occurs if the amount recorded to the credit of the Replenishment Ledger
sufficient new after the application of the Available Distribution Amounts in accordance with the Revolving Period Priority of Payments on the two
underlying exposures (2) consecutive Payment Dates exceeds 10 per cent. of the Aggregate Discounted Balance on the Closing Date (as set out in item
for replenishments (d) of the definition of “Revolving Period Termination Event” in section 24 “GLOSSARY OF CERTAIN DEFINED TERMS”, subsection
under revolving 24.2 “Definitions” of the Preliminary Prospectus).
Transactions
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 22 of 30# Criterion Article 21 (7) Verification Report
34 Clear rules in the Transaction Verification Method: Legal (Transaction documents)
documentation regarding
The Servicing Agreement provides for a clear specification of the contractual obligations, duties and responsibilities of the
obligations, tasks and respon-
Servicer, especially with regard to the servicing, monitoring, reporting and monthly advances to mitigate for commingling risk, as
sibilities of the Servicer, trustees
well as the provisions for a potential replacement in case of a Servicer Termination Event.
and other ancillary service
providers Similar provisions for the obligations, duties and responsibilities of the Data Trustee, Security Trustee, Account Bank, Issuer
Administrator (Intertrust (Netherlands) B.V.), Issuer Auditor and Paying Agent (Elavon Financial Services DAC) are provided for in
the respective descriptions in the Preliminary Prospectus.
The transaction documentation clearly specifies provisions that ensure the replacement of the Account Bank. If the Account Bank
ceases to have the Required Credit Rating as set out in section 6.4 “Account Bank” of the Preliminary Prospectus as well as in the
Account Agreement.
The Swap Agreement includes provisions that ensure the replacement of swap counterparties upon rating downgrade of the swap
counterparty below a specified threshold, failure to make payments due under the Swap Agreements and the occurrence of
certain insolvency events, see section 8.5 “Swap Agreement”, item “Termination” of the Preliminary Prospectus. Furthermore,
detailed provisions exist for the obligations, duties and responsibilities of the Swap Counterparty (see section 8.5 Swap
Agreement of the Preliminary Prospectus)
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 23 of 30# Criterion Article 21 (8) Verification Report
35 Experience of the Servicer Verification Method: Regulatory (suitable proof) / Legal (Transaction documents) / Due Diligence
(management and senior staff)
Athlon Car Lease Nederland B.V. as the Seller and Servicer of the Transaction has well documented and adequate policies,
in the servicing of exposures of
procedures and risk-management controls relating to the servicing of the Purchased Assets originated under the respective
a similar nature to those
underlying Lease Agreements in place.
securitised
The business of Athlon Car Lease Nederland B.V. acting as Servicer and Seller has included the origination and underwriting of
exposures similar to those securitised for more than five (5) years, please refer to section 13 “THE SELLER AND THE SERVICER”,
subsection 13.1.1. “Description of the Seller” of the Preliminary Prospectus.
The experience and expertise of the management and the senior staff of the Seller has been confirmed during the Due Diligence.
As a result, the Seller as the Servicer is deemed to have the relevant expertise as an entity being active as servicer of Lease
Receivables and as servicer of Lease Receivables securitisations for more than five years, and no contrary findings were observed
during the STS verification process for the Transaction.
# Criterion Article 21 (8) Verification Report
36 Appropriate and well documen- Verification Method: Regulatory (suitable proof) / Due Diligence
ted risk management and
As a result of the regulatory status (see #35 above), Athlon has well established procedures with regard to risk management,
service policies, procedures
servicing and internal control systems in place.
and controls
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 24 of 30# Criterion Article 21 (9) Verification Report
37 Clear and coherent definitions, Verification Method: Legal (Transaction documents) / Due Diligence
regulations and possible
The Credit and Collection Policy of Athlon Car Lease Nederland B.V. (see section 13.2 “Credit and Collection Policy” of the
measures with regard to the
Preliminary Prospectus), which must be complied in respect of the servicing of the Lease Receivables and the Leased Vehicles by
servicing of non-performing
the Servicer in accordance with the Servicing Agreement (as summarised in section 8.4 “Servicing Agreement” in the Preliminary
exposures, specification of the
Prospectus) contains a description of procedures related to:
priorities of payment
• Credit underwriting process
• Servicing and collection procedures
• Credit risk management
• Reporting
The loss definition used in the Transaction refers to the term „Defaulted Lease Agreement” which means a Lease Agreement:
• in respect of which:
(i) the relevant Lessee is in arrears with respect to any Lease Instalment by more than 90 days from its due date;
or
(ii) the Servicer has made specific provisions in the relevant accounts or has written off the Lease Receivables
resulting from such Lease Agreement in the relevant accounts in accordance with the applicable accounting
principles; or
(iii) an Insolvency Event relating to the Lessee has occurred,
and
• which has been terminated.
This definition is consistently used in the Transaction documents.
The Transaction documents clearly specify the priorities of payment, see sections “Revolving Period Priority of Payments”,
“Normal Amortisation Period Priority of Payments” and “Accelerated Amortisation Period Priority of Payments” of the Preliminary
Prospectus, and after a Notes Acceleration Notice by the Security Trustee has been delivered, the priorities of payment will
change to the “Accelerated Amortisation Period Priority of Payments”. The event will be reported in the investor report.
The procedures presented and discussed in the Due Diligence correspond to the description in the Transaction documentation and
no contrary findings could be observed.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
Page 25 of 30# Criterion Article 21 (10) Verification Report
38 Clear rules in the event of Verification Method: Regulatory / Legal (Transaction documents)
conflicts between the different
The transaction documentation provides for clear rules in the event of conflicts between the different classes of noteholders, see
classes of noteholders
in particular clause 11. “Meetings of Noteholders; modification; consents; waiver; removal director” of the Preliminary Prospectus.
The Notes are governed by Dutch law. Please refer to "Risk relating to conflict of interest between the interests of holders of
different Classes of Notes and Secured Creditors" in the Preliminary Prospectus.
# Criterion Article 22 (1) Verification Report
39 Provision of historical perfor- Verification Method: Legal (Transaction documents) / Due Diligence
mance data before pricing
The historical performance data relate to the portfolio of auto lease receivables granted by the Seller, including closed-end and
open-end lease, relating to Leased Vehicle (see clause 9 “DESCRIPTION OF THE PORTFOLIO” in the Preliminary Prospectus). The
historical performance data provided by the Seller include the following areas:
Gross Defaults measured as gross cumulative default rates based on the amount of originated leases per quarter since
origination in static format (covering the period from Q1 2015 until Q4 2020) and for the total portfolio.
Delinquencies measured as quarterly delinquency rate based on the cumulative delinquent principal balance and arrears as of
outstanding portfolio (covering the period from Q1 2015 until Q4 2020), for the total portfolio in the respective delinquency
bucket (1-30 days past due, 30-60 days past due, 60-90 days past due and >90 days past due).
Sales proceeds (book value and number of cars sold for total portfolio) in static format (covering the period from Q1 2015 until
Q4 2020) for the total portfolio and include charges for end of contract damages, insurance results and sales costs.
Early Termination rate (annualised and 12M rolling average) in static format (covering the period from January 2015 until
December 2020) for the total portfolio.
The data history, which is provided prior to pricing, covers a period of at least 5 years required under Article 22 (1) of the
Securitisation Regulation.
Given that the most relevant factors determining the expected performance of the underlying exposures in the securitised
portfolio, namely the factors described in #24, are the same to the overall portfolio for which the above mentioned historical
performance data have been procured, comparability between the securitised portfolio and the Seller’s overall portfolio
(“substantially similar exposures”) is ensured.
Silver Arrow Athlon NL 2021-1_SVI_Preliminary Verification Report
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