Rating-Agency & Regulatory Liaison in Structured Finance

Securing an investment-grade rating or navigating complex regulatory approvals can feel like threading a needle in a hurricane. One missed assumption, and funding costs spike. One overlooked rule, and your deal stalls. Clients tell us they’ve spent weeks wrestling with rating-agency comments—only to see their transaction timeline slip away. We take on that burden, coordinating every query and preempting potential roadblocks, so your securitization, ABS or project-finance transaction proceeds without drama.

Engaging Early with Rating Agencies

We initiate contact with S&P, Moody’s and Fitch at the earliest structuring phase. Draft assumptions and narrative materials arrive in their inbox before they ask, demonstrating preparedness and earning trust. In a recent $350 million CLO, our early-model submission resolves 75 percent of standard questions by day 3. That head start cut the agency review from four to two weeks—and translated into a 10 bps spread improvement.

Each agency has its own playbook: average-life tests, interest-rate shocks, recovery-rate benchmarks. We build a comparison matrix to track all methodologies side-by-side. When assumptions diverge—perhaps Moody’s requires a higher default assumption than S&P—we discuss trade-offs with your team, acknowledging that no single model captures every nuance of your pool. That transparency builds credibility and smooths out conflicting feedback.

Managing Regulatory Filings Across Jurisdictions

Whether your deal must comply with SEC Form F-3, European Prospectus Regulation or local ECA documentation, we prepare each dossier with precision. Regulatory calendars are tight: a missed filing window can push an issuance into the next quarter, undermining pricing. One energy-infrastructure client recently faced a two-week delay on an EBA template error. Our proactive pre-filing review flagged the issue in advance—saving that deal from stumbling at the last hurdle.

Some jurisdictions demand bespoke disclosures. In Asia, regulators may request additional environmental-impact data for a renewable-energy securitization. Our network of local counsel ensures those requirements are integrated into the offering memorandum and investor presentation, reducing back-and-forth and providing confidence to global investors.

Streamlining Agency Q&A and Amendments

After initial submissions, questions cascade in from multiple reviewers. Instead of managing email threads, we host a dedicated portal that tracks each question’s status, responsible party and deadline. This single source of truth prevents duplicate answers and ensures your team responds at pace. Clients report that this approach cuts their internal time spent on agency Q&A by over 50 percent.

Amendments are inevitable. Whether an unexpected regulatory change or an agency-requested covenant tweak, our legal and structuring teams coordinate to draft, negotiate and finalize amendments in lockstep—often within 48 hours of identification.

Typical Liaison Workflow & Timeline

Stage	Activities	Duration
Initial Engagement	Submit model assumptions, narrative decks, key covenant language	Days 1–3
Agency Review	Consolidate questions; host weekly calls; update assumptions	Weeks 1–2
Pre-Filing Compliance	Prepare regulatory dossiers (prospectus, ECA docs, filings)	Weeks 2–3
Final Sign-Off	Obtain rating letters; file final documents; issue securities	Week 4

Overcoming Common Challenges

• Conflicting Agency Feedback: We facilitate a “triage” session, aligning your view on key assumptions and documenting rationale for regulators.
• Late Regulatory Changes: Our change-control process ensures any new requirements are assessed immediately and integrated without derailing timelines.
• Document Version Overload: Version-control protocols and a centralized cloud repository guarantee everyone works from the latest draft.