S&P Global (China) Ratings has assigned its preliminary AAA_spc(sf) rating to the Senior Notes of the Jianxin 2020-7 Non-performing Asset Backed Securities transaction to be issued by China Construction Bank Trust Co., Ltd. (CCB Trust) and originated by China Construction Bank Corp (CCB).

We assigned the preliminary rating based on information as of November 17, 2020. We expect to assign and publish our final rating when the trust becomes effective.

Based on recovery data provided by CCB between July and October 2020, the actual recovery of the asset pool performed well. As of the end of October 2020, total recovered cash accounted for 80.1% of the senior notes to be issued.

The preliminary rating reflects our opinions according to the analysis of five pillars under S&P Ratings China--Structured Finance Methodology:

Credit Quality of the Securitized Assets: We analyzed the originator’s operation model, non-performing loan management policy, collection ability and historical experience, static pool and related data performance, securitized asset features and actual recovery performance. We estimated the recovery rate for the portfolio to be 13.65% under our AAA_spc(sf) rating stress scenario.

Payment Structure and Cash Flow Mechanics: Based on the cash flow analysis and stress testing, we expect senior notes to be able to pay principal and interest on time and in full under the current notes’ rating, transaction structure and related assumptions. Our analysis and stress scenarios for the transaction include various combinations such as recovery amount, recovery timing, interest rate and expenses. Under our most stressed scenario, the final S&P Global (China) Ratings CE buffer is 0%.

Operational and Administrative Risk: The servicer CCB has rich experience in managing NPL securitization products. We believe the bank’s IT infrastructure and operation model are capable of fulfilling the duties and responsibilities stipulated in the agreement. Although there is no back-up servicer on this transaction, the transaction will set aside a cash reserve to provide liquidity support. Besides, the transaction is exposed to collection agency due diligence risk, but we believe the participants in this transaction are capable of fulfilling the duties and responsibilities stipulated in the agreement given their experience and past track record.

Counterparty Risk: Our assessment of counterparty risk takes into account payment interruption risk, account bank risk, commingling risk and set off risk etc. The transaction documents have incorporated various credit quality triggers to mitigate the abovementioned counterparty risk.

Legal and Regulatory Risk: We believe the special purpose trust’s legal structure meets the principle of true sale and bankruptcy remoteness in securitization. Through our legal analysis, risks related to borrower notification, statute of limitation on recovering credit card debt, conflict of interest and other legal risk have been sufficiently mitigated by the arrangements stipulated in the transaction documents.

List of Preliminary Ratings:

Senior Notes: AAA_spc(sf)

Methodology Applied:

• S&P Ratings China--Structured Finance Methodology

Related Research:

• Commentary: Understanding Our Approach to China Consumer Asset-Backed Securities

• Commentary: Mega Banks – Strong Enough to Withstand COVID-19: 2020 Outlook for Chinese Mega Banks

• FAQs on Banks’ Nonperforming Assets and Securitization

Media Contacts:

Sharon Tang, Beijing, (86)10-6569-2988; sharon.tang@spgchinaratings.com

Analyst Contacts:

Beibei Shi, CFA, Beijing; beibei.shi@spgchinaratings.cn

Jiarong Li, Beijing; jiarong.li@spgchinaratings.cn

Jieqiong Du, Beijing; jieqiong.du@spgchinaratings.cn

(Note: This document is prepared in both English and Chinese. The English translation is for reference only, and the Chinese version will prevail in the event of any inconsistency between the English version and the Chinese version.)