Investors Beware of Brazilian FIDCs (ABS) Backed by Consumer Credit
Investors in Brazilian ABS backed by consumer loans should be wary of increasing levels of non-performing loans (NPLs) in Fundos de Investimento em Direitos Creditórios (FIDCs). LatAm Structured Finance has warned about this before (www.latamsfc.com). Evidence the situation is worsening includes the following recent developments in Brazil.
- Central Bank of Brazil surprises markets and lowers SELIC 50 basis points.
- Banks increase reserves and provisions for bad debt to record levels.
- FGC Helps to Sanitize the Financial System
What are the implications for investors? New-issue investors need to evaluate carefully the issuing entity’s portfolio for the quality of debt underwriting and the entity’s ability to service the loans. Investors that currently hold FIDCs need to monitor the credit portfolio’s performance carefully.
We see weakness in consumer loans issued by banks and finance companies and we have no doubt that this is the single thread that unites some of the otherwise contradictory economic news in the Brazilian press.
Both the Central Bank of Brazil (BCB) and the Fundo Garantidor de Crédito (Credit Guarantee Fund, FGC) have been working behind the scenes to contain the growing problems from NPLs and to prevent a full blown credit crisis in Brazil.
FIDCs do not have this government protection. FIDC credit quality has deteriorated since the beginning of the year according to data we pulled from Orbis, a structured finance database and news service from Uqbar. Of the 250 FIDCs in the Orbis system with data for the last seven months, 77% have seen increases in provisions for bad debt (PDD – Provisões Devedores Duvidosos). PDD increased more than 100% since the beginning of the year in 29 FIDCs. Fifteen of those deals were either multiple market or multiple segment deals. Due to lack of transparency in the Brazilian ABS market, it is better to look directly at the credit markets themselves to understand these trends.
Putting Together Pieces to Understand Brazil’s Credit Markets
The August 30 meeting of the COPOM, the monetary committee for Brazil’s central bank (BCB), dramatically altered the general perception of the economic picture in Brazil when they cut SELIC by 50 basis points. Most analysts were caught by surprise; however, our calculations show that the market had been forecasting approximately an 80% chance of a 25 basis point interest rate cut on August 29. The COPOM has since been criticized from many corners for lowering the rate even though Brazilian inflation has not yet retreated.
The market now expects the COPOM to cut SELIC to about 10.25% by June 2012, while analysts polled by the BCB survey are divided between 10.50% and 10.75% as the low, as you can see in the first graph below. Both the market and economists now view the BCB as very accommodative. The BCB conveniently cites the growing problems in Europe as the motive for cutting rates. We don’t believe that’s their main motivation. In our view, the BCB and the Brazilian Government are more worried about the growing problems with consumer credit at home and about protecting the banking system. This explains why the BCB cut rates at the risk of losing control of inflation and some credibility with the international financial community.
We have been warning that the Brazilian financial system is showing signs of strain due to the extraordinarily high growth in consumer credit balances and the high level of consumer NPLs since May 2011. Government’s efforts to rein in the growth this market have failed. We also pointed to the evidence that payments on consumer loans are not sufficiently large enough to amortize the principal. As a result loan balances continue to grow in spite of declining issuance (See our Second Quarter Review).
The Brazilian press continues to point to the overall low levels of non-performing loans and occasional reductions in the levels of non-performing loans. We put these reports in the basket labeled “misleading statistics.” As with FIDCs, the overall numbers in the financial system are obscuring some important developments in the sub-sectors. Most importantly, there is a growing number of NPLs on the consumer portfolios of both banks and non-bank finance companies.
Smaller Brazilian banks have encountered difficulties in managing their balance sheets since the 2008 global credit crisis. These banks find it difficult to sell parts of their credit portfolios to the larger banks because the large banks have tightened up their credit underwriting standards, especially after the Banco PanAmericano scandal. The graph below indicates two dangerous trends. First, NPLs continue to run much higher than 2008/2009. Second, the lagged but sudden increase in NPLs in bank portfolios indicates that the problems in consumer credit portfolios for non-bank finance operations seem to be affecting or “contaminating” the bank consumer credit portfolios.
Estado de São Paulo announced in a September 15 edition that the Fundo Garantidor de Créditos (FGC) had realized “sanitation operations” of around R$7.5 billion this year to clean up problems with some medium and small sized banks. The most recent operation transferred Banco Matone to Grupo JBS, thanks to support of R$850 million from the FGC. The other big “sanitizing operation” for 2011 was a R$1.5 billion package help BMG absorb Banco Shahin. That leaves roughly R$5 billion more in other operations that have been used to shore up other banks. FGC currently has resources of a little more than R$26.8 billion. This means that the fund has spent about 25% to 33% of its resources to prop up the financial system this year.
It is clear that the BCB and the Brazilian government are trying to avoid a panic. An editorial in Estado de São Paulo points out that the FGV’s operations have two advantages promoted by Brazil’s Central Bank: they don’t involve public money and they are discreet. The operation’s discretion prevents depositors from panicking about the financial health of other banks. The editorial points out that this helps reduce systemic risk in the Brazilian financial system.
At the end of August we produced a report that analyzed the recent actions taken by Brazilian banks to shore up reserves and increase provisions for non-performing loans. (See “At What Height Does A Bank Seawall Protect From a Credit Tsunami?”) The biggest Brazilian private and government banks have been increasing loan loss provisions and reserves to almost unheard of levels. Caixa Econômica Federal is provisioning 300% of NPLs. Given that banks recover on average 30% to 40% of bad debt, with the range spanning from 5% to 60% of the value of loan, a provision of 300% of NPLs seems like overkill unless the bank knows something that the public doesn’t. Brazilian banks execute “renegotiation operations” that banks in other countries would normally consider bridge loans for defaults. The BCB would know if banks are entering into these types of agreements frequently.
Summarizing the condition of the FIDC Market
This brings us to the FIDC market in Brazil. The statistics are deceptively reassuring. As the graph below demonstrates, the overall PDD level has been fairly stable. It appears that the problems in the consumer credit market have not yet affected FIDCs in general. As with the banking system, we believe the overall statistics are hiding the problems. Statisticians often quote the paradox of a person drowning in a river that is on average 5 inches deep. We believe that the distributions are skewed and that the averages are hiding problems.
We used data from Orbis to calculate the percent change PDD from January to July 2011 and plotted the data in the histogram in the fourth graph below. We took out all of the deals with extraordinary changes over 500% to error on the side of caution in our calculations. PDD increased by more than 25% in more than 47.6% of the FIDCs over this period, even with our conservative approach.
Part of this artificial stability stems from the issuer’s ability (and common practice) to buy back loans that are more than 90 days past due. However, the CVM has passed new rules (Instruction 489) that will severely limit the balance sheet options for issuers who repurchase substantial amounts bad loans from FIDC credit portfolios. In addition, the banks will not have the balance sheets to continue this practice if the credit markets continue to deteriorate. We believe this picture will worsen as the economy slows down more.
As stated in the opening, new issue investors need to evaluate carefully the issuing entity’s portfolio for the quality of debt underwriting and the entity’s ability to service the loans. Investors that currently hold FIDCs need to monitor the credit portfolio’s performance carefully for the near future.
As bank portfolios deteriorate in quality and larger banks rein in issues, smaller banks will have more incentive to sell loans into FIDCs. Investors in FIDCs backed by short term credit, such as factoring receivables, need to be especially vigilant. These revolving FIDCs experience large turnover and the credit quality can drop dramatically in one month. Any sudden jumps in PDD or sharp increases in late payments (Créditos Vencidos e Não Pagos – CVNP) should be investigated quickly. This information can be found on the Informe Mensal on the CVM website.
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