Fitch Rates Capital Auto Receivables Asset Trust 2015-3
--\\$197,000,000 class A-1a notes 'AAAsf'; Outlook Stable;
--\\$131,000,000 class A-1b notes 'AAAsf'; Outlook Stable;
--\\$227,000,000 class A-2 notes 'AAAsf'; Outlook Stable;
--\\$227,000,000 class A-3 notes 'AAAsf'; Outlook Stable;
--\\$86,640,000 class A-4 notes 'AAAsf'; Outlook Stable;
--\\$50,940,000 class B notes 'AAsf'; Outlook Stable;
--\\$48,260,000 class C notes 'Asf'; Outlook Stable;
--\\$42,900,000 class D notes 'BBBsf'; Outlook Stable;
--\\$53,620,000 class E notes 'BB-sf'; Outlook Stable.
Subsequent to Fitch's presale publication, Ally Financial Inc. (AFIN) decided to split the A-1 notes into classes A-1a and A-1b.
KEY RATING DRIVERS
Stable Collateral Characteristics: The 2015-3 pool is representative of nonprime collateral, with a 633 weighted average (WA) Fair Isaac Corp. (FICO) score, 8.8% WA APR and 105% WA loan-to-value (LTV) ratio. Of the pool, 60% consists of new vehicle contracts, while extended-term contracts total 77%, all relatively consistent with recent securitized pools.
One-Year Revolving Period Risk: The revolving structure introduces risk of collateral migrating to a weaker pool before the start of the amortization period, although eligibility criteria pertaining to the additional receivables may mitigate some of this risk. Fitch accounts for collateral migration in its derivation of the base case loss proxy for 2015-3.
Adequate Credit Enhancement: Initial hard credit enhancement (CE) for class A notes totals 19.5%. The non-declining reserve is 0.50%, subordination totals 18.25% and initial overcollateralization (OC) is 0.75%, growing to a target of 2.25% after the revolving period. The expected excess spread totals 5.08% per annum.
Stable Portfolio Performance: AFIN's nonprime auto loan portfolio performance has improved relative to the weak 2006?2008 period, given the gradual improvements in the U.S. economy and health of the used vehicle market. Fitch's base case loss proxy for 2015-3 is 5.50%. However, Fitch's current CNL extrapolations for outstanding CARAT transactions which have begun to amortize is 3.00% to 3.50%.
Stable Corporate Health: Fitch currently rates AFIN 'BB+'/'B'/Outlook Stable. AFIN demonstrates solid capabilities as an originator, underwriter and servicer, as evidenced by its historical prime and nonprime portfolios and securitization performance.
Legal Structure Integrity: The legal structure of the transaction should provide that a bankruptcy of AFIN would not impair the timeliness of payments on the securities.
Unanticipated increases in the frequency of defaults and loss severity on defaulted receivables could produce loss levels higher than the base case. This in turn could result in Fitch taking negative rating actions on the notes.
Fitch evaluated the sensitivity of the ratings assigned to Capital Auto Receivables Asset Trust 2015-3 to increased credit losses over the life of the transaction. Fitch's analysis found that the transaction displays some sensitivity to increased defaults and credit losses. This shows a potential downgrade of one or two categories under Fitch's moderate (1.5x base case loss) scenario, especially for the subordinate bonds. The notes could experience downgrades of three or more rating categories, potentially leading to distressed ratings (below 'Bsf') or possibly default, under Fitch's severe (2.5x base case loss) scenario.
DUE DILIGENCE USAGE
Fitch was provided with third-party due diligence information from Deloitte & Touche LLP. The third-party due diligence focused on comparing or re-computing certain information with respect to 225 loans from the statistical data file. Fitch considered this information in its analysis, and the findings did not have an impact on the analysis. A copy of the ABS Due Diligence Form-15E received by Fitch in connection with this transaction may be obtained through the link at the bottom of this rating action commentary.
Fitch's analysis of the Representations and Warranties (R&W) of this transaction can be found in the reports titled 'Capital Auto Receivables Asset Trust 2015-3 -- Appendix'. These R&W are compared to those of typical R&W for the asset class as detailed in the special report 'Representations, Warranties, and Enforcement Mechanisms in Global Structured Finance Transactions' dated June 12, 2015.