Can RT217, RT218, RT222 and RT223 be redacted from public reporting of internal RMBS for all swap types?
Yes, these can be redacted from the public version.
Questions & Answers
Data Availability
If a value appears in RT256 (Warranty Repurchases), is this value double counted in RT113 (Outward Substitution Principal Amount)?
No, RT256 would not be double counted. Outward substitutions should capture outward flows from the pool other than the other defined fields like Warranty Subs (i.e. if the loan no longer meets eligibility criteria but hasn't breached a warranty). So the set of flow items in the pool node should be a complete set and none of the values should be duplicating each other.
For securities with coupon payment frequencies of greater than one month, what reporting is required?
Monthly reporting is required for all securities, including those that have a coupon payment frequency greater than one month. The reporting date should be on the monthly anniversary of the regular payment date. For any fields relating to distributions these should be recorded as zeros ("0") if no distribution is set to occur in that reporting period.
What does the RBA consider as ‘new’ dwellings?
A dwelling type which had not been previously occupied would be considered as ‘new’.
If a repurchased loan is closed out does this need to be reported?
If a loan exits the pool then limited fields for that loan must still be reported for the period in which the loan exited the pool. The fields to be reported are: RL001, RL002, RL003, RL004, RL009, RL010, RL012, RL013, RL026, RL049, RL054 and RL055.
Can you please advise if the RBA has a tolerance threshold for fields where we lack information for a small percentage of loans in a transaction?
The RBA will make an allowance for a small amount of missing data in information providers' reporting. This will be determined case by case.
With relation to RL082 Bankruptcy Flag, we can only identify whether a borrower has been in bankruptcy within 7 years of origination, not the requested 10 years. How should this field be recorded?
When a bankruptcy history is not available past 7 years prior to the loan settlement date, the RBA is willing to accept an answer based on 7-year history. In this situation, please mark ‘True’ if a borrower was bankrupt at any point within 7 years prior to the loan settlement date, otherwise indicate ‘False’. If a 7-year history is not available please refer to the 'No Data' policy in the table outlining implementation arrangements.
When income details are not collected for some loans, is it acceptable to use one of ‘No Data’ response options for RL090 and RL092 Income?
Please refer to the ‘No Data’ policy in the table outlining implementation arrangements.
RL083 Last Credit Discharge Date might be only available for borrowers discharged from bankruptcy within 7 years prior to the loan settlement date, due to data availability issues. In this case, how should this data field be filled out?
When a bankruptcy/ discharge history is not available past 7 years prior to the loan settlement date, the RBA is willing to accept answers based on 7-year history. In this situation, mark ‘N/A’ if none of the borrowers to the loan have recorded a default or bankruptcy within 7 years prior to the loan settlement. If a 7-year history is not available please refer to the ‘No Data’ policy in the table outlining implementation arrangements.
Is the RBA going to add more data fields in data templates in the future?
There will be no further changes to the RMBS data requirements ahead of 30 June 2015. If there are any changes to data requirements after this date, industry will be given a minimum of six months lead time to implement any changes.
The RBA has included ‘No data’ (ND) options in data templates. For data fields completed with ‘No data’ options, can you confirm that we will not be required to provide missing data by 30 June 2015?
From 30 June 2015 onwards, the No Data 1 (ND1 – data not collected at origination), No Data 5 (ND5 – Data not applicable) and No Data 6 (ND6 – Data not collected reason being Pending Sale (RL053)) replies will be the only permitted use of ‘No Data’ replies for any missing data. If, after 30 June 2015, a large number of data fields feature ND1 replies, the Bank reserves the right to make the security ineligible for repo.
As a bankruptcy check from external credit agencies is not mandatory in our loan processing, data field RL082 will be unavailable for significant proportion of our loans. What should be done for this data field?
The ‘No data’ 1 (ND1) option can be used in such a case since the data are not collected at the loan origination and processing stages. Please refer to the ‘No data’ policy in the table outlining implementation arrangements.
What ‘No Data’ response is acceptable for data not collected at loan origination?
If the data are not collected at loan origination, ‘ND1’ would be an acceptable ‘No Data’ response.
What ‘No Data’ response is acceptable for data collected at loan application, but then only stored in hard copy format (i.e. not in any electronic system)?
If the data are collected at loan origination but are not stored in any electronic system, ‘ND2’ would be an acceptable ‘No Data’ response.
Is it ok to derive scheduled balance of a loan using actual loan balance and amount of prepayments?
The scheduled balance of a loan can be estimated as long as it is consistent with the description provided by the RBA in the loan-level template.
How do I fill out Maturity Date data field if a loan maturity date changes as a result of redraws by a borrower?
Even though certain data fields, such as Maturity Date, have a ‘static’ reporting frequency, related data should be amended when there is updated information available.