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A Primer On China's Residential Mortgage Backed Securities Market

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A Primer On China's Residential Mortgage Backed Securities Market

Since S&P Global Ratings assigned its first rating to a China-based residential mortgage-backed security (RMBS) transaction in 2018, this sector has been attracting increasing attention from offshore investors. We believe one draw is the longer weighted-average tenor offered by RMBS relative to other securitization assets in China.

In our view, it's imperative that market participants in RMBS, particularly offshore investors, gain a holistic view of China's housing market, mortgage market, and RMBS sector. We provide an overview of all three in this report.

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1. China Housing Market Overview

1.1. Property type and ownership

Property types: Urban high-rises predominate in China's residential markets 

China's urban development model relies heavily on high-rise residences for land-use and environmental purposes. Hence most mortgage loans are for units in apartments or high-rise complexes. Stand-alone houses and developments also exist but constitute a much smaller part of the market.

Due to years of almost continual price appreciation, regulators have long layered the market with restrictions to keep housing within an affordable range, especially for first-time homebuyers. Size is used as a gauge when setting such housing restrictions and associated regulations. In China, developers often rely on pre-sales to obtain cash to complete the construction of development projects. For this reason, the stage-of-development is important to watch in this RMBS market.

Property types include: 

Ordinary and non-ordinary housing.   A major distinction between the two is floor size. In general, the first type is defined by regulators as floor size no greater than 144 square meters, among other criteria, while the second type is floor size greater than 144 square meters. This distinction is worth noting because different compliance rules and tax rates may be applied for non-ordinary housing.

New (including forward-delivery) and existing homes.  For new homes, registered contracts of sale are an important source for mortgage originators to decide the loan-to-value (LTV) ratio. For existing homes, banks usually consider the lower of sale price and property appraisal by a third party when determining the LTV ratio.

Completed houses and forward delivery houses.   A completed house is one with certificates of house ownership and land use rights. It is ready for delivery. A forward delivery house is clearly defined in the context of mortgage loan origination. The definition is that when a building is topped out (i.e. its roof is sealed), a bank can apply for an advance registration notice of mortgage and disburse a mortgage loan based upon such notice. The time taken to complete construction for delivery is typically a few months to two years. When the house is completed and associated certificates become available, the bank has the priority right to register a typical mortgage on the house. In our view, mortgage loans extended against forward delivery houses are exposed to construction risk.

In China, we do not rate RMBS whose underlying pools include mortgage loans on forward-delivery houses. Hence our rated RMBS are not exposed to construction risk of the underlying properties.

Ownership: China has a leasehold system 

Homeowners in China are entitled to the property ownership and the land-use rights granted through leases. The two together constitute the property rights. The ownership of the residential land belongs to the state. There is no private land ownership under Chinese law.

The lease term for much of China's residential land is 70 years. In other rare cases, the lease term may range from 20 years to 50 years. According to the regulators, the 70-year leases will be automatically renewed when they expire.

Property rights in China are governed by Part II (Property rights) of China's Civil Code.

1.2 Housing price trend

Restrictive policies set to maintain price stability 

Housing prices have largely remained stable after having cooled off since 2017 in terms of indices, when regulators implemented stricter rules to curb fast growing property prices and speculation in the property market. That said, there were still some price volatilities observed in various cities from time to time. Over the long term, China's policy will be guided by the principle that "housing is for living, not speculation". We estimate national residential property sales will shrink by 15%-20% in 2022 because of a 10-15 percentage point decrease in volume and a near 5 percentage point drop in home prices.

In China's major (or tier-one) cities, prices have stagnated since 2018, with nearly flat year-on-year (yoy) price growth. Initially some momentum shifted to tier-two and tier-three cities, but the growth rates there have gradually tempered as well. In the past 12 months, growth rates of the average property prices in tier-two and tier three cities remained at or below 5% (see chart 1).

Chart 1

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1.3. Property location

Property markets are sharply differentiated by region 

Like in most Asian countries, China's properties located in city centers and downtown areas are usually prime and in high demand. Unlike markets with suburban housing sprawl, such as in the U.S. and Australia, the key residential markets are urban in China.

Due to large wealth gaps within China, regional property markets vary greatly depending on factors such as local population trends, income, and economic growth. Housing supply and demand, and consequently average selling prices, vary from city to city too.

Beijing, Shanghai, Guangzhou, and Shenzhen are classified as tier-one cities. They are four of 70 cities tracked by the government on residential-property indicators including average selling prices and sales volume. Cities are classified as tiers one, two, and three for mortgage-disclosure and other purposes. However, market participants devise their own categorizations as well; so other than for tier-one cities, the tiers and ranking can vary among private rankings.

Regional markets see differentiated local policies 

China's property market remains strictly managed by the Chinese central government under national rules. However, the "one city, one strategy" policy continues to be rolled out in more and more cities since its introduction in 2019. In 2022, there were more cities, such as Nanjing and Suzhou, which eased home purchase requirements for non-local residents. Such loosening policies are usually measures by municipal governments to attract talent to work and settle down in their cities.

2. Mortgage Market

2.1. Mortgage originators

Two types of financers provide mortgage loans in China, namely banks and house provident funds (HPF). Six banks dominate the market.

Chart 2

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China's top six banks account for around 70% of bank-financed residential mortgages 

The aggregate measures of China's five large state-owned commercial banks are good indicators for the bank-financed mortgage loan segment, in light of the banks' aggregate market share and nationwide branch network. Postal Savings Bank of China Co. Ltd. (PSBC), one of the six-largest commercial banks in China by total assets, plays a unique position in the county and rural banking market.

HPF serves qualified obligors with cheaper funding 

The mandate of HPF is to help low- to middle-income households by extending cheaper home loans. Employees are required to contribute a proportion of their monthly salaries to the fund, with employers contributing certain amounts. Contributors to the fund can apply for preferential-rate mortgage loans, withdraw funds to pay for housing repairs and maintenance costs, and pay for rent if certain conditions are met. The People's Bank Of China (PBOC) occasionally adjusts the preferential benchmark rate. The rate is currently 3.25% for loans over five years, compared with 4.45% base rate for ordinary mortgage lending at around the same tenor.

2.2. Size

The outstanding balance of bank-originated mortgage loans reached RMB38.3 trillion by the end of 2021 (see chart 3). The aggregate size of China banks' mortgage loan portfolio has increased by more than four times in less than a decade.

The market expanded rapidly from 2015 to 2017, with outstanding mortgage loans growing more than 35% in early 2017, the fastest ever. Regulators responded by implementing much stricter controls over the property and mortgage markets to curb speculation. Criteria for both housing purchases and mortgage lending were greatly tightened. The growth rate for mortgage loans immediately slowed (see chart 3).

Chart 3

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2.3. Product types and related features

By lenders.   Home loans, depending on the originators, are classified into bank loans, HPF loans, and "combo" loans. A combo loan refers to homebuyers borrowing via both HPF and a bank. This is common because despite the low cost, HPF loans are usually subject to strict rules for maximum limits and may not fully meet the funding needs of borrowers.

In most Chinese RMBS transactions, the securitized assets are bank loans.

Principal repayment method.  Principal is repaid in equal monthly instalments or equal principal repayments. In most of the Chinese RMBS transactions we rate, the weighting of equal monthly instalments versus equal principal repayments is 80%-20%.

Mortgage rates.  The loan prime rate (LPR) is the current base rate. The Chinese central bank implemented a new loan pricing regime in 2019, replacing the PBOC lending rates with LPR as the new base rate for mortgage loans. The effective mortgage rate is calculated as the LPR plus or minus a fixed spread, with a floor at LPR for first-home mortgage loans and a floor at LPR plus 60 basis points for second-home mortgage loans. The regime was initially rolled out in 2019 to new mortgage loans only. The conversion of the existing mortgage loans to the LPR rate took effect from March to August 2020. Depending on the tenor of the mortgage loan, a bank can choose either the five-year or the one-year LPR as the base rate. The rates are reset each month by PBOC based on quotes from a panel of participating banks. The latest quote of the five-year and one-year LPR was 4.45% and 3.70%, respectively, as of May 20, 2022.

PBOC lending rates were the previous reference.   Prior to the shift to LPR, the PBOC five plus year lending rate was the most commonly used base rate for mortgage loans. If a loan's tenor was no longer than five years, PBOC's one to five year lending rate would be the base rate. Under the PBOC pricing regime, the mortgage rate was calculated as the PBOC lending rate adjusted by a fixed multiplier. The PBOC rates are 4.9% and 4.75% for five-plus-year lending and one- to- five-year lending, respectively.

Base rate resetting.   Under the LPR regime, the rate resetting period shall not be shorter than one year. Based on common market practices, mortgage rates are generally reset at the beginning of the next year or on the anniversary of the last reset.

Loan tenor.  Initial term to maturity can go up to 30 years. In practice, most tenors are not this long, due to restrictions; e.g., the maximum total of the loan tenor and the age of the borrower cannot exceed 65 years. For existing homes, more thresholds such as test of property age may apply, further limiting the loan tenor.

In our observation, initial loan tenors commonly range between 20 and 30 years. And initial loan tenors of less than five years are rare. The government's policies on mortgage loan tenors have not changed much in recent years.

Notable features.  The mortgage loans offered in China are straightforward and homogenous. Notable features associated with mortgage loans are:

  • Home insurance is uncommon.
  • Interest-only periods, teaser periods, and mortgage insurance are rare.
  • Mortgage refinance or balance transfer is rare, partly due to regulatory restrictions. In addition, mortgage rates among banks in the same region are usually not much different and hence provide no incentive for borrowers to refinance through another bank to lower mortgage rates. The regional banking association sets minimum lending rates as reference for banks in each regional market.
  • Redraw facility is not allowed.
2.4. Regulatory dynamics

Regulators.   The PBOC and China Banking and Insurance Regulatory Commission (CBIRC) are the main regulators.

The Ministry of Housing and Urban-Rural Development is in charge of property-related matters. It has from time to time released rulings and guidance jointly with the PBOC and CBIRC regarding the housing and mortgage market.

Key regulations in relation to mortgage lending  

Debt-to-income test.   Mortgage borrowers have to meet the criteria for income as a proportion of debt, according to the "Commercial Bank Real Estate Lending Risk Management Guidance," issued in 2004, by the forerunner of the CBIRC. The key measures of debt-to-income assessment are:

  • Monthly mortgage payment over monthly income is equal to or less than 50%; and
  • Monthly debt payment over monthly income is equal or less than 55%.

Loan-to-value ratio.  Chinese homeowners have to put down a lot of cash to get a mortgage loan. According to the PBOC's regulatory requirement, the LTV ratio to apply in mortgage lending needs to observe the following rules:

  • For first-home purchases, the general rule of the maximum LTV ratio is 80%. The LTV ratio is subject to lower cap in certain conditions, such as 70% for the purchase of home subject to purchase restrictions or with floor size over 90 square meters.
  • For second-home purchases, the maximum LTV ratio cannot exceed 70%. If the second home is non-ordinary housing (for example, housing size exceeding 144 square meters), the maximum LTV ratio could be lowered even further.

Forward delivery house.  For forward delivery house, a loan can be disbursed only after the associated building is topped out and the meeting of other conditions. To secure the mortgage rights over forward delivery house, banks usually require registration of an advance pledge under their name before loan disbursement.

2.5. Underwriting criteria

PBOC Credit Bureau check and score card.   The PBOC administrated Credit Bureau provides personal and entity credit records that can be accessed by banks for credit checks. A nationwide credit system was first implemented in 2006, and covered about 1 billion people by 2019. With an upgrade beginning in 2020, the second generation of the system is said to have enhanced key functions including information quality, usefulness and security. In addition to PBOC credit checks, banks also use their in-house score card systems to facilitate credit underwriting. With pre-embedded underwriting criteria, the score card system can automatically score a loan application and classify it into a relevant risk level. Based on the outcome, the system can either automatically approve/reject an application, or assign it to a credit officer for manual review.

Debt-to-income ratio.   Banks in China adopt the debt-to-income (DTI) test as the affordability measure in underwriting mortgage loans. This is in compliance with regulatory requirements.

In calculating monthly debt payments, banks usually refer to the PBOC's credit bureau records and HPF sponsored-mortgage loans. The PBOC's credit records normally include debt with financial institutions such as banks and auto finance companies. With PBOC's credit bureau system 2.0 launched in 2020, banks further expanded data sources in their credit scoring system and can incorporate borrowers' debt obligations with most fintech companies for calculating debt payments.

The household net income is used in calculating DTI, with income taxes excluded. For salaried borrowers, stamped income letters and bank statements are mostly used as proof of income. For private-enterprise employees or self-employed borrowers, additional documents such as business licenses may be required. The banks may conduct phone inquiries or online checks to verify employment authenticity. For rental or investment incomes, documents such as rental contracts and investment certificates need to be provided.

Loan-to-value ratio.   Banks in China strictly follow the PBOC's guidance on the LTV ratios. The maximum LTV in China is 80%, and available only for first-home purchases in general. For second home purchases or properties located in markets subject to purchase restrictions, more conservative LTV ratios are applied. The definition of second-home purchase includes scenarios of both second mortgage and first mortgage for a second home when the borrower's first home remains on hand.

According to data reported by sample banks in China, the LTV ratios for first-home and second-home purchases have both declined since 2017. The tightening was in correspondence with stronger regulatory restrictions on the property and mortgage markets. Although there has been some selective loosening of LTV restrictions since the fourth quarter of 2021 under regulatory guidance to stabilize house prices amid the real-estate downcycle, the loosening appears mostly in small cities and limited to first-time buyers. For first-home mortgage loans, 70% LTV remains the dominant market trend. For second-home mortgage loans, 60% LTV was losing steam while 50% and 40% LTV were rising quickly.

Property appraisal.   The property value for a new home is based upon "registered" contract of sale. If banks believe the registered contract of sale to be higher than the market level, they could apply a lower property value. A contract of sale and sale price needs to be registered and therefore can be found online via websites managed by China's real estate-related government agency.

For an existing home, a third-party property appraisal report is required. The selection of appraisal vendors and procurement of appraisal services are usually centralized.

2.6. Mortgages

In China, the most common form of security granted over real estate is a mortgage. A bank mortgage lender must execute in writing through either the signing of a separate mortgage agreement by the mortgagor (the borrower) and the mortgagee (the bank), or co-signing of the mortgage loan agreement incorporating terms of the mortgage by the mortgagor.

In addition, the mortgage lender must register the mortgage with the real estate-related government agency to create a valid mortgage right over the associated residential property. This is why typically a mortgage lender would check if a mortgage registration is made before the lender disburses the loan backing a residential property with a title certificate.

2.7. Servicing

Borrowers are required to set up auto-debit bank accounts for monthly repayment before loan disbursement. This is an industry practice.

Besides collection, the servicing scope also includes ongoing monitoring of the loan book's performance conducted by dedicated servicing teams set up by banks at their headquarters and in branch offices. Risk models and behavior scorecards are the most frequently adopted approaches to identify risks before potential delinquencies. Based on the early alerts generated by the monitoring system, the branch servicing team or relationship managers will follow up with borrowers.

Property reappraisal is often required one year after loan disbursement, mostly as part of banks' internal risk-monitoring activity. After the first-time reappraisal, banks can decide the future re-appraisal frequency.

2.8. Arrear management

Based on our observation, bank mortgage lenders take notification action prompted by the number of days overdue and risk level. They tend to first send out text messages, followed by automatic voice-system calls in the first few days after a loan becomes delinquent.

If a loan remains in early delinquency, which usually means less than 90 days past due, banks might phone, send out warning notices, or visit delinquent borrowers in person.

If a loan becomes more than 90 days overdue, or exhibits higher risk to recovery in the bank's view, the mortgage lender would take legal action via a court process.

Chinese bank mortgage lenders also use third-party collection agencies to conduct outbound calls or contact delinquent borrowers in person. In our view, the in-person approach appears to be susceptible to measures such as social distancing or lockdown amid the recent COVID-19 pandemic.

2.9. Foreclosure process

Mortgage lenders can work out defaulted loans through the courts or directly.

In a non-court process, borrowers may cure the default by repaying the arrears with money from other sources or settle the debt with proceeds from selling their homes. If a dispute is brought to court, the legal proceeding will run through litigation, ruling, enforcement, and liquidation through auction. The foreclosure costs typically are borne by the defaulting borrowers in accordance with typical loan agreements.

The non-court process to recover defaulted loans seems more common, in our observation. This route is cheaper and faster. Experiences by China's major banks indicate that defaulted loans can be worked out in less than one year through a non-court process, compared with one to three years or even longer if through the court process.

We estimate potential costs of the court process to be 10%-12% of the loan principal amount. Our estimated costs include expenditures such as court-related fees (3%-4%), attorney fees (3%-7%), and stamp duties (0.05%) borne by seller. Our estimate is based on the official processing fees schedule, as well as actual costs incurred in a sample of past legal cases.

While banks can foreclose on a property, the court might not allow the bank to seize the property. According to the Supreme People's Court, a property in foreclosure may not be auctioned if that property is necessary for the associated borrower and family for living. This may lengthen the foreclosure period. However, in an updated supreme court ruling in 2015, liquidation may be granted if the bank promises to use some of the proceeds to provide the defaulting borrower with five to eight years of rent for public rental housing. This updates give mortgage lenders more flexibility to resolve a default loan.

3. China's RMBS Sector

3.1. Issuance size

China's RMBS issuance rebounded to RMB499 billion in 2021, which is similar to the pre-COVID 2019 level, and a 18% increase from the RMB424 billion in 2020. In 2021, 62 new deals were issued, similar to the 55 in 2020 and 66 in 2019.

Chart 4

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The fluctuation in issuance volume and number of transactions in recent years may be attributed to bank originators' continued need for balance-sheet management and regulatory stance toward the property market. For banks, RMBS issuance can free up their balance sheets to increase lending when market demand for mortgage loans is rising, without breaching regulatory requirements. That was a major explanation for 2018. In 2019, after a year of unprecedented issuance growth, and amid weakening demand from the mortgage market, repeat issuance from large banks dropped. However, the number of first-time transactions from small and midsize banks has risen, making RMBS a more widely used tool for balance-sheet management among banking participants in recent years.

3.2. RMBS as a funding source for mortgage loans

RMBS in China has not yet had a meaningful impact on the mortgage market. The utilization rate of RMBS, as measured by outstanding RMBS divided by total outstanding bank-sponsored mortgage loans, has continued to rise year over year; however, the ratio remains less than 5%.

We believe the RMBS market in China still has meaningful growth potential in the long run. However, we may observe a moderate dip in issuance in 2022 because of a 15%-20% drop, by our estimate, in residential property sales in 2022 and regulatory shift. In addition, demand from banks to utilize RMBS to manage their balance sheets may change from time to time, depending on the loan demand.

3.3. Key issuers

The RMBS market is dominated by two large commercial banks, namely China Construction Bank and Industrial and Commercial Bank of China. Their combined total issuance accounted for over 70% before 2019 and has remained at above 50% in recent years. Activity was relatively solid for first-time issuers and repeated issuance from other banks.

Banks that have issued 10 RMBS transactions or more (as of end-2021) include Bank of China, China CITIC Bank, Industrial Bank, China Merchant Bank, Bank of Communications and Bank of Hangzhou.

3.4. How do investors acquire a legal interest in the collateral?

RMBS issuers in China transfer the assets by a true sale to a trust company, which issues beneficiary certificates to investors.

The legal structure of the trust is established as a special-purpose trust (SPT) under China's Trust law, and is in full compliance with the PBOC's credit assets securitization (CAS) scheme and CBIRC's governance. The legal structure of the SPT meets our criteria for asset true sale and insolvency remoteness.

3.5. Key legal risks and mitigants in Chinese RMBS from a rating perspective

Loan transferability.  According to article 545 Part III (Contracts) of China's Civil Code, a loan can be transferred to a third party unless restricted by contract. In our rated RMBS transactions, we observed that the loan agreements used for the securitized mortgage loans do not prohibit those loans from being transferred. This is typically covered by legal due diligence and confirmed by the legal due diligence finding.

Notification to borrowers of the mortgage pool.   The originator must announce the establishment of the SPT and asset transfer in nationwide media in accordance with article 12 of the Administrative Measures for the Securitization of Credit Assets. However, individual borrowers are not notified at trust settlement. As a result, the transfer of the loans is legally effective between the originator and the trustee; it however does not extend to the borrowers. This leaves a legal loophole, should the originator/servicer become insolvent and the borrowers continue to make payments to the originator acting as the servicer. Typically a transaction is structured to mitigate such risk by requiring a minimum rating on the originating bank/initial servicer, and if the rating on the bank falls below the minimum requirement then notifications will be sent to individual borrowers for redirecting payment to the trust account directly.

No mortgage reregistration at closing.   When the mortgage pool is transferred to the trust, the mortgages in relation to the loans will not be reregistered. The originator is still the registered first-ranking beneficiary. Without mortgage reregistration at deal close, the trustee on behalf of the trust still has mortgage rights. This is according to article 407 of Part II (Property Rights) in China's Civil Code; the associated rights can't be separated from the debts attached by those rights.

3.6. Asset performance

Chinese RMBS transactions exhibited healthy and stable performance. The cumulative default rates of Chinese RMBS transactions by annual vintages remained mostly below 0.8% as of end-2021 (see chart 5). Future performance may be subject to knock-on effects from rising defaults among China's property developers because construction risk may rise, thus affecting mortgage loans backed by forward delivery houses, which are common among China RMBS.

Moreover, China's low tolerance to COVID points to strict localized lockdowns. The volatility of the delinquency rates of our rated deals could increase in the next few quarters, in our view. The resurgence of the pandemic and the resulting short-term lockdowns in various regions in China are likely to lead to liquidity issues for borrowers that are self-employed or work in the service and hospitality industries. Also, lockdowns affect in-person collection efforts, which are mainly used for recovering severe delinquencies.

Having said that, favorable pool attributes underpin the sound performance of RMBS. The diversified nature of the underlying pools in the RMBS transactions and favorable pool attributes, such as a low weighted average current LTV ratio and long weighted average loan seasoning, are key pillars of stable performance in our rated RMBS transactions in China.

Chart 5

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The weighted average constant prepayment rate (CPR rate) of bank-originated RMBS transactions was 7%-9% in the fourth quarter of 2021, which is lower than the mid-teens level a few years ago (see chart 6). CPR could fluctuate between 6% and 10% in the medium term as uncertainties in the property sector may loom over property sales volumes.

Fluctuations of the CPR largely depend on the momentum of second-hand property sales. The prepayment rate usually drops when the second-hand property market becomes less active.

Chart 6

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3.7. Capital structure

The capital structure used in Chinese RMBS is not complex.   In Chinese RMBS transactions the senior tranche usually has three to four classes of notes ranking equally, namely class A-1, class A-2, class A-3 and class A-4. Following those, there may or may not be a mezzanine tranche and then a subordinated tranche. The ratings are usually assigned to the senior notes and the mezzanine notes.

Separate interest and principal waterfalls.   RMBS transactions in China commonly adopt separate interest and principal waterfalls. A principal draw is allowed to cover liquidity shortfalls when needed. Principal collections available after covering liquidity shortfalls will be used to pay down notes either in accordance with soft amortization schedules or in a pass-through manner.

Sequential payment is mostly used.   The senior and mezzanine notes will receive interest payments on a regular basis. The available interest-collections will first pay to the senior notes coupons and then the mezzanine notes coupons. Among the notes ranked equally, their interest payments will be paid on a pro-rata basis. The principal payments will also follow the sequential pay, in which the senior notes will receive the payment first, followed by the mezzanine notes if the senior notes have been fully repaid, and at last the subordinated notes when the mezzanines notes are redeemed in full.

Soft amortization schedule and acceleration event triggers.   Our rated RMBS transactions usually adopt soft amortization schedules for the class A-1 and class A-2 notes. For the class A-3 and class A-4 notes, a pass-through is used. When an acceleration event is triggered, such as a rise of cumulative default rate over a certain threshold, the payments among the class A notes will switch to pro-rata.

Credit enhancement.   Primary credit enhancements come in the forms of note subordination, and excess spread when it exists. In addition, our rated RMBS transactions also have liquidity reserves and principal-draw feature to meet short-term liquidity risks.

China RMBS Rated By S&P Global Ratings

Related Research

This report does not constitute a rating action.

Primary Credit Analysts:Andrea Lin, Hong Kong + 852 2532 8072;
andrea.lin@spglobal.com
Patrick Chan, Hong Kong + 852 2533 3528;
patrick.chan@spglobal.com
Secondary Contact:Jerry Fang, Hong Kong + 852 2533 3518;
jerry.fang@spglobal.com

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