Risk Divestiture Strategies for Whole Loans, Financial Asset Portfolios & Business Platforms

Whether you are looking to divest financial assets due to economic, operational or regulatory pressure, Mayer Brown offers innovative solutions. We are one of only a few firms that has both the breadth to provide a true one-stop shop for counsel on financial products and services and the depth of experience to respond to volatile markets and rapidly changing conditions.

Mergers & Acquisitions

• Assured Guaranty in its acquisition of FSA from Dexia, including the novel use of derivatives to provide sovereign support to FSA.
• Bayview Asset Management in its acquisition of Pingora Holdings, L.P., a specialized asset manager focused on investing in new production of performing mortgage servicing rights and servicing residential mortgage loans, from Annaly Capital Management.
• Caliber Home Loans in its acquisition of substantially all of the business assets and certain pipeline loans from a regional mortgage company, including consumer regulatory due diligence on the target.
• Carrington Capital Management in its approximately $170 million acquisition of the mortgage servicing platform of New Century Financial Corp. Carrington was approved as the stalking horse bidder in this 363 transaction by the Delaware bankruptcy court.
• Cornerstone Mortgage in the sale to Guild Mortgage of Cornerstone's mortgage origination platform and its portfolio of Fannie Mae, Freddie Mac and Ginnie Mae mortgage servicing rights.
• A hedge fund manager in structuring a joint venture with an asset manager to enter into a distressed sale of non-performing residential mortgage loans and residential REO properties from a struggling thrift.
• Guaranteed Rate, Inc. in connection with the acquisition by a joint venture established by Guaranteed Rate and Realogy Holdings Corp. of certain assets of PHH Home Loans' mortgage operations, including mortgage origination and processing centers, corporate relocation division and a substantial majority of employees across the United States.
• Ocwen Financial Corporation, who along with Walter Investment Management Corp. was awarded the winning bid for the mortgage loan origination business of Residential Capital LLC (ResCap) in a bankruptcy court-sponsored auction for a purchase price of $3 billion, a matter that M&A Advisor named the 2013 “M&A Deal of the Year” in the “Over $1 Billion” category.
• Redwood Trust in its $490 million acquisition of CoreVest American Finance Lender LLC, a leading nationwide originator and portfolio manager of business-purpose residential loans, from Fortress Investment Group LLC and certain management holders. 
• Värde Partners, Inc. in its acquisition (2014) and subsequent sale (2019) of Deephaven Mortgage LLC,. a leader in the Non-Qualified Mortgage loan industry, to Mortgage Origination Holdings, LLC, a subsidiary of Pretium Partners, LLC.
• Wells Fargo & Company in its $1.75 billion sale of certain commercial and retail auto loans in Puerto Rico from the loan portfolios of its Reliable Financial Services and Reliable Financial Holding Company subsidiaries to Banco Popular de Puerto Rico. Banco Popular also acquired certain other assets relating to Reliable's auto financing business.
• Wells Fargo & Company in its $32 billion acquisition of the commercial distribution finance and vendor finance business of General Electric Capital Corporation with assets in North America, Europe, Asia, Australia and New Zealand.
• WMIH Corp. as regulatory counsel in the $3.8 billion merger with Nationstar Mortgage Holdings Inc., the Texas-based mortgage servicing company

Recapitalizations and Restructurings

• Represented the securitization facility administrator and L/C bank, a leading global bank, in connection with the A/R-based DIP facility, and A/R-based exit facility, in connection with the Chapter 11 cases of Arch Coal and its affiliates.
• Represented the administrative agent, in a complex cross-border ABL Facility in which the UK Borrowers, Bristow Norway AS and Bristow Helicopters Limited, a British helicopter operator and its Norwegian subsidiary, in connection with the pre-packaged Chapter 11 of its parent.
• Represented a leading global bank, as administrative agent, with respect to a prepetition accounts receivables securitization facility, A/R-based DIP facility and A/R-based letter of credit exit facility, in the Chapter 11 cases of Cloud Peak and certain of its affiliates and subsidiaries.
• Represented the administrative agent and lender for certain prepetition, DIP, and exit accounts-receivable securitization facilities totaling approximately $2 billion, in the aggregate, in connection with the pre-packaged Chapter 11 cases of J.G. Wentworth Company and its affiliates.
• Represented a leading UAE banking and financial services corporation, in connection with the preservation of parent guarantee supporting bilateral facility, in connection with the Chapter 11 cases of McDermott International, Inc. and its affiliates.
• National Asset Management Agency (“NAMA”) the Irish bad bank (Irish: Gníomhaireacht Náisiúnta um Bhainistíocht Sócmhainní), with regard to over a £1 billion of assets in a range of restructurings from some of the country’s largest house builders to international investors.
• Represented the bond trustee in connection with the successful restructuring of Odebrecht Oil & Gas and its subsidiaries and affiliates. At issue were two defaulted bond indentures with outstanding notes totaling more than $2.7 billion ($400 million and $2.3 billion, respectively).  The engagement was recognized as the “Restructuring Deal of the Year” by both the International Financial Law Review and the Latin Lawyer.
• Represented a leading global bank, as DIP joint-lead arranger, with respect to a $5.5 billion DIP facility in the Chapter 11 cases of PG&E Corporation and its primary operating subsidiary, Pacific Gas and Electric Company.  Also, represented two other leading global banks with respect to their respective positions in the prepetition bond supporting letter of credit facilities.
• Represented a leading global bank, as administrative agent on behalf of four overlapping but different syndicates of lenders, with respect to the restructuring, refinancing, and exit of several secured loans totaling approximately $500 million in principal, in the Chapter 11 cases of Procure Cancer Treatment Centers and its affiliates, which included innovative use of the municipal bond market to facilitate exit financing (both out-of-court and in connection with a prepackaged Chapter 11) and, separately, through a highly contested section 363 bankruptcy sale process.  Awarded “Chapter 11 Reorganization of the Year ($500 MM to $1B)” at the M&A Advisor’s 2019 Annual Turnaround Awards and “Health Care Services Restructuring Deal of the Year” at the Global M&A Network’s 2019 Annual Turnaround Atlas Awards.
• Represented a market leading institutional trust company and a major U.S. bank, as administrative agent and DIP agent for two separate syndicates of lenders, respectively, with respect to a $49 million DIP facility in the Chapter 11 cases of Waypoint Leasing Holdings Ltd. and its various subsidiaries.  This deal was awarded “Restructuring of the Year ($1B to $10B)” at the 2019 M&A Advisor Turnaround Awards.

Whole Loans

Whole Loans – Mortgages 

• 25 Capital Partners as both a seller and purchaser of non-performing residential loans, REO properties and seasoned loans.
• Ally Bank in the $556 million sale of a portfolio of residential mortgage loans to DLJ Mortgage Capital, Inc., a subsidiary of Credit Suisse Group AG.
• Banco Popular de Puerto Rico, as seller, lender and administrative agent, in the sale and subsequent financing of non-performing residential mortgage loans, residential REO properties, commercial REO properties and non-performing commercial loans.
• New Residential as purchasers and sellers of residential mortgage loans.
• Pacific Trust Bank as seller in several whole loan sales of performing residential mortgage loans and as purchaser in several whole loan purchases of re-performing residential mortgage loans.
• RMS as originator and servicer in connection with a whole-loan sale of EBO HECMs.
• A Spain-based bank in its acquisition of performing loans from a US private equity firm.
• SunTrust in the sale of non-performing and seasoned whole loans to GSEs, investment banks and other financial institutions.
• Varadero Capital, L.P. in connection with its purchase of performing commercial mortgage loans from Cantor Commercial Real Estate. The loans were financed on a repurchase facility provided by Citibank, N.A. that closed concurrently with the loan purchase. The transaction was Varadero Capital’s first entry into the commercial mortgage loan market and the first of several planned purchases to aggregate and securitize commercial mortgage loans.
• Värde Partners, as purchaser and seller of non-performing, seasoned and newly originated residential mortgage loans.
• Waterfall Asset Management in connection with whole-loan purchases of proprietary reverse mortgage loans.
• Waterfall Asset Management in its acquisition from GE Capital of $516 million of small business commercial mortgage loans financed concurrently in a securitization with Credit Suisse without bridge financing.
• Numerous other major financial institutions, funds and other mortgage originators in confidential mortgage loans and similar assets.

Mortgage Servicing Rights (MSR)

• A national mortgage servicer in connection with the sale of residential mortgage servicing rights related to mortgage loans held by Fannie Mae and Freddie Mac with aggregate outstanding balances of $32 billion.  
• A banking and financial services company in the sale of mortgage servicing rights related to reverse residential mortgage loans held by Fannie Mae or backing securities guaranteed by Ginnie Mae with aggregate balances in excess of $14 billion to a residential mortgage loan service provider.
• Lakeview Loan Servicing, LLC., as purchaser of Fannie Mae, Freddie Mac and Ginnie Mae servicing rights in a coordinated program of more than 150 purchases from multiple sellers through bulk and flow transactions, covering servicing rights related to residential mortgage loans with aggregate balances in excess of $250 billion.
• Lakeview Loan Servicing, LLC in the purchase from PHH Mortgage Corporation of servicing rights related to residential mortgage loans backing securities guaranteed by Ginnie Mae with aggregate balances in excess of $14 billion.
• A mortgage lending services provider in the sale of substantially all of its mortgage servicing rights portfolio, representing unpaid principal balances of approximately $25 billion, to a residential mortgage lender.
• Wells Fargo Bank in connection with its purchase from Seneca Mortgage of mortgage servicing rights related to residential mortgage loans held by Fannie Mae and Freddie Mac with aggregate balances in excess of $51 billion.

Consumer – Other than Mortgages (Student Loans, Auto Loans, Credit Cards, etc.)

• Alecta, a Swedish asset manager, on their investment in an SEK 1 billion portfolio of unsecured consumer loans which were originated by a Swedish fintech platform called Lendify.
• Ally Bank in the sale of its portfolio of performing and non-performing student loans to Southern Arc Trust, a newly formed subsidiary of Credigy Investments LLC.
• Represented bidders for performing and distressed credit card portfolios, including bids for the Target, Advanta Bank and Sterling Jewelers portfolios.
• Represented funds managed by CarVal in connection with the acquisition of credit card receivables from Signet Jewelers and a related servicing arrangement.
• Seller’s counsel to Charming Shoppes and securitization counsel to Comenity Bank in the acquisition by Comenity Bank of the Charming Shoppes credit card portfolio and related master trust.
• A fund in connection with flow purchases of prime and near-prime unsecured marketplace consumer loans from Lending Club.
• A fund in connection with obtaining a $150 million warehouse credit facility from a major financial institution to finance unsecured marketplace consumer loans originated by Marlette Funding.
• Goldman Sachs Bank USA as purchaser in a forward-flow student loan purchase transactions with CommonBond, Inc. 
• A hedge fund in the acquisition of a portfolio of private student loans from Navient Corporation.
• A hedge fund in the sale of a portfolio of private student loans to Citizens Bank, N.A.
• A hedge fund in a consumer loan flow purchase arrangement from Applied Data Finance.
• A large issuer of major brand bank card products in connection with a sale of MSRs to Ocwen.
• LendingClub, a pioneer in the peer-to-peer lending market, as sponsor, seller and servicer in fractional participation platform sold to various investors. This transaction was the first to include LendingClub’s own originated loans sold on a fractional participation basis.
• A major financial institution, as initial purchaser, sole structuring advisor and lead bookrunner, in connection with the issuance of $175 million fixed rate notes backed by marketplace loans originated by WebBank, purchased and serviced by Avant, subsequently purchased by SPVs owned by KKR- and Victory Park Capital-managed funds and issued through a KKR-VPC JV and grantor trust structure.
• A major leading consumer finance company in separate small business loan joint ventures with On Deck Capital and Kabbage.
• A major financial institution in a facility to fund purchases by Stone Ridge of marketplace loans from SoFi and LendingClub.
• Santander Consumer USA in the sale of assets from its personal lending portfolio to an undisclosed buyer. The portfolio was comprised of installment loans with an unpaid principal balance of approximately $900 million.
• Santander Consumer USA in connection with its $1.1 billion acquisition of a portfolio of auto loans originated by Gateway One Lending & Finance, LLC on a servicing-released basis.
• Square, a leading small business lender operating on an online bank platform, on over 20 whole loan trades of small business loans.
• Square, as a PPP lender under the CARES Act, and Celtic Bank Corporation on structuring a bank partner arrangement whereby the PPP loans originated under the terms of that arrangement have been sold in flow arrangements to third-party investors. 
• Upstart Network Inc. on its whole loan sales of consumer loans as well as on capital markets transactions. 
• A well-established US Investment Manager on an investment in the UK non-performing loan market.  Our involvement comprised advice in relation to the acquisition of several portfolios of non-performing consumer and credit card receivables together with advice related to the acquisition of a servicing platform in order to manage collections of the receivables.
• Wells Fargo & Company in the sale of the residual auto loan portfolio owned by Reliable Financial Services, Inc., a subsidiary of Wells Fargo & Company and former provider of commercial and retail auto lending services, to Wheels Holdings, LLC
• Numerous other major financial institutions, funds and fintech companies in confidential whole loan sales of unsecured personal loans and similar assets.

Commercial Loans

Corporate, Secured, Unsecured and Pools of Loans

• Carlyle Investment Management on multiple acquisitions of management contracts on a total of $7 billion of collateralized loan obligations.
• FCS Advisors and Brevet Direct Lending, as administrative agent and lender, in a warehouse loan facility to fund online small secured business loans by BusinessLoan.com, LLC.
• A hedge fund, in a multiple-draw term loan facility to SPV subsidiary of MyBusinessLoan.com, LLC, to finance the SPV borrower’s purchase of online small business loans originated by MyBusinessLoan.com, LLC.  This transaction also involved taking a warrant to purchase 5 percent of the company. 
• A hedge fund in two secured revolving loan facilities financing the purchase of online small business loans originated by or for On Deck Capital, Inc.
• A major financial institution in establishing a registered ’40 Act fund to invest in marketplace consumer and small business loans.
• A major financial institution in establishing a registered ’40 Act fund to invest in marketplace consumer and small business loans.
• A major fund in connection with a facility to purchase interests in commercial loans from a community bank.
• A private equity asset manager on the acquisition of a large portfolio of distressed European real estate assets, as well as the related joint venture and third-party financing arrangements.
• A UK-based financial institution, which along with a syndicate of international investors, acquired a loan portfolio from a Lithuanian bank. This is the largest foreign-led transaction to occur in Lithuania to date.
• Wells Fargo & Company in its acquisition of WestLB’s subscription finance portfolio, which contained approximately $6 billion in commitments (with approximately $3 billion outstanding). The representation included the due diligence on both the US and EU loans in the portfolio, the negotiation of the definitive purchase agreement, and the underlying assignments of each of the deals at the loan level.
• Numerous other major financial institutions, funds and fintech companies in confidential whole loan sales of commercial loans and similar assets.

Financings & Securitizations

Mortgage Loans

• Amherst Holdings in the first securitization of a mortgage note created in a seller-financed disposition of single family rental properties.
• The Carlyle Group, as seller, in non-agency residential mortgage warehouse facilities.
• Carrington Capital Management L.L.C. in the securitization of non-performing mortgage loans, re-performing mortgage loans and non-qualified mortgage loans.
• Carrington Mortgage Services, LLC, as seller, in several bankruptcy-protected repurchase facilities of newly originated loans.
• CarVal, as seller, in connection with several repurchase warehouse facilities of residential mortgage loans and residential REO properties.
• Deephaven Mortgage in multiple issuances of notes backed by residential mortgage loans, including an inaugural RMBS deal by a non-prime, non-QM mortgage originator.
• Finance of America in multiple issuances of notes backed by HECM loans.
• Oaktree Capital Management, L.P., Seer Capital Management L.P. and Western Asset Management Company, LLC in connection with multiple issuances of notes backed by non-QM residential mortgages, including their inaugural issuances.
• PennyMac, as seller, in several bankruptcy-protected repurchase agreements involving conforming residential mortgage loans, non-performing residential mortgage loans and residential REO properties and rehypothecated residential mortgage loans.
• Pretium Mortgage Credit Partners I Acquisition, LP and the fund's affiliates in connection in the acquisition and securitization of for approximately $8.0 billion pool of non-performing residential mortgage loans in nineteen transactions between 2014-2019.
• Redwood Trust in the acquisition of a junior participation interest in residential mortgage loan warehouse facility. 
• Several Redwood entities, as sellers, with several bankruptcy-protected repurchase facilities of newly originated loans.
• Waterfall Asset Management in connection with the issuance of its inaugural HECM-backed securitization as well as the issuance of two securitizations of seasoned proprietary reverse mortgage loan pools and one securitization of a new-originated proprietary reverse mortgage loan pool.
• Affiliates of Waterfall Asset Management, as seller, in connection with a repurchase warehouse facility for proprietary reverse mortgage loans.
• Värde entities, as sellers, in a repurchase facility with loans held in a REMIC structure.

Financings & Securitization MSR Transactions

• A mortgage lending services provider in the sale of substantially all of its mortgage servicing rights portfolio, representing unpaid principal balances of approximately $25 billion, to a residential mortgage lender.
• A leading mortgage servicing company in connection with a senior secured term loan facility secured by MSRs, among other collateral.
• Home Loan Servicing Solutions in connection with its acquisition and financing of MSR-related assets Plaza Home Mortgage, Inc. in connection with a term loan facility used to fund acquisitions of residential mortgage loan servicing rights.
• Principal Residential Mortgage in connection with a structured financing supported by mortgage servicing rights.
• Wells Fargo in its purchase from Seneca Mortgage Servicing LLC of mortgage servicing rights related to residential mortgage loans held by Fannie Mae and Freddie Mac with aggregate balances in excess of $51 billion.

Financing & Securitizations Student Loans, Auto Loans, Credit Cards

• Student Loans

• A syndicate of financial institutions in connection with a $750 million warehouse credit facility to finance unsecured private student loans held by a special-purpose affiliate of Sallie Mae Bank.
• A major financial institution in connection with a $150 million warehouse credit facility to finance unsecured private student loans held by a special purpose affiliate of Earnest Operations LLC.
• A major financial institution in connection with a $250 million warehouse credit facility to finance unsecured private student loans held by a special purpose affiliate of NelNet.
• A major fund as investor in connection with a $300 million student loan securitization sponsored by SoFi Lending Corp.
• A bank, as sponsor, and DRB Prime Student Loan Trust 2015-D, as issuer, in the issuance of $332.5 million student loan asset-backed notes.

• Auto Loans

• Capital One, National Association, as issuer’s counsel, in connection with the issuance of two prime auto loan ABS transactions. These transactions represented the relaunch of Capital One’s auto ABS program, which had been dormant since the credit crisis.
• CPPIB and Global Lending Services on a GLS auto loan securitization where GLS complied with risk retention by creating a majority-owned affiliate structured to be consolidated with GLS on GLS’s balance sheet even though it was majority owned by CPPIB). This transaction was one of the first uses of majority-owned affiliate structures to finance risk retention in auto ABS.   
• Flagship Credit Acceptance in structuring, negotiating and documenting the first-ever financing of auto ABS retained interests intended to comply with the risk retention rules.  The securitized assets were subprime auto loans. 
• Santander Consumer USA Inc. (“Santander Consumer”), as issuer’s counsel, in connection with a $918 million revolving auto loan ABS transaction. We believe this was the first revolving ABS transaction structured with soft-bullet maturities backed by sub-prime auto assets.
• The underwriters in a public offering of $1.6 billion auto-loan-backed notes issued by Toyota. Proceeds of the TFS “Green Bond” are being used to fund new retail finance contracts and lease contracts for Toyota and Lexus vehicles that meet specific criteria, including powertrain, fuel efficiency and emissions. 

• Credit Card

• The investors in connection with a $175 million private placement of fixed rate notes secured by dollar-denominated Visa, MasterCard and American Express merchant voucher receivables sold by Banco Guayaquil S.A. This transaction was awarded Deal of The Year: Structured Finance and Securitisation at the IFLR Americas Awards 2020.
• RBC Capital Markets, LLC and other dealers, as placement agents, in Fairstone Financial Inc.’s inaugural ABS transaction totaling CND$322.44 million. Fairstone is Canada’s largest non-bank provider of responsible lending solutions for near-prime and non-prime borrowers. The deal was marketed both in Canada and the U.S., and marks the first-ever personal loan ABS transaction in Canada.
• The senior lender in the first securitization of Canadian credit card receivables by a non-bank credit card issuer.
• Synchrony Financial in the issuance by Synchrony Card Issuance Trust of $1 billion of SynchronySeries Class A(2018-1) Notes, the first tranche of notes publicly issued in the SynchronySeries.  The SynchronySeries Card Issuance Trust is the only new de-linked credit card master trust formed to publicly issue asset-backed notes backed by credit card receivables in over a decade. 

Miscellaneous

• A major financial institution as underwriters’ counsel for a 144A offering of ABS backed by two major fund’s loans acquired from Avant.
• A major financial institution as underwriters counsel in a 144A offering of ABS backed by loans acquired by a hedge fund Prosper Marketplace.
• A leading financial services firm in its role as one of three lead investment banks providing and arranging the financing for the acquisition of Chrysler by Cerberus.  To finance its acquisition, Cerberus raised approximately $47 billion in the asset-backed securities market through several securitization facilities covering auto loans and leases, dealer floor plans and other assets.  We represented our client in the structuring and distribution of these facilities.  This is the largest use of ABS ever to finance an acquisition.
• Island Finance, the largest Puerto Rico unsecured personal loan business, in a securitization financing by a group of banks led by Credit Suisse for the acquisition by JC Flowers of Island Finance from Banco Santander.
• Morgan Stanley and Citigroup as arrangers and lead managers on a €540 million CMBS transaction. The transaction is the securitization of a loan which was used to fund Blackstone’s €1.8 billion acquisition of Sponda, which is Finland’s largest real estate company.  The transaction was the first ever CMBS out of Finland and the first ever dual EU and US risk retention compliant CMBS transaction. 

Financing & Securitizations Commercial Loan Transactions (CLOs & Corporate)

• Citi as underwriter, frequently also acting as deal counsel, on numerous cash-flow CLOs of broadly syndicated loans managed by collateral managers such as BlackRock, Octagon, PGIM, Guggenheim, Fidelity, KKR, GSO/Blackstone, Wellfleet Capital and Aegon.
• HPS Investment Partners, LLC and its majority-owned affiliates as investment manager with respect to open market CLOs, including with respect to EU Risk Retention Compliant CLOs, refinancings and resets.
• MJX Asset Management LLC and its majority-owned affiliates as collateral manager with respect to open market CLOs, including with respect to EU Risk Retention Compliant CLOs, refinancings and resets.
• Overseas Private Investment Corporation, a US government agency, as the lead investor in a $175 million collateralized loan obligation securitization by responsAbility Financial Inclusion Investments 2019 DAC, a designated activity company incorporated in Ireland.  The issuer used the proceeds of the securitization to fund a portfolio of underlying loans to be made to financial institutions in emerging markets around the world to support their microfinance and small or medium business lending programs.
• Natixis Securities Americas and SG Americas Securities as placement agents on the inaugural $596 million middle market collateralized loan obligation transaction for Owl Rock Capital Corporation.
• Natixis Securities Americas LLC and certain of its subsidiaries as placement agent of secured notes and as initial purchaser of revolving notes in connection with a $600 million CRE CLO secured by whole commercial mortgage loans and funded participations in commercial mortgage loans. The transaction is managed, which allows for additional unidentified assets to be purchased into the structure during both Ramp-up and Reinvestment Periods. The transaction also featured a $50 million AAA-rated revolving tranche and is the first post-2008 crisis CRE CLO to feature a revolving class.

Synthetic Transfers

• Deal counsel for a global US financial institution on a $500 million structured deposit with Bank of Ghana (the central bank). The deposit was secured over a portfolio of the Central Bank of Ghana’s foreign government bond holdings held with the Bank of New York Mellon in London. The deal was unique and used complex dynamic collateralisation technology to manage the credit risk associated with the bond portfolio. The deal raised com­plex issues of sovereign immunity, cross-border security enforcement, the Financial Collateral Arrangement Regulations and capacity and authority of a central bank.
• A Mexican subsidiary of a Spanish bank on the synthetic securitization of a portfolio of Mexican SME Loans through a guarantee structure. This sophisticated structure used credit derivatives technology to provide regulatory capital relief to the bank. The counterparty was a multilateral institution. This is a highly-complex matter, requiring deep technical knowledge of derivatives to facilitate the synthetic securitization of the loan portfolio. This was the first deal of its kind successfully executed in Mexico.
• A financial services company in a $1 billion credit-linked note issuance backed by a pool of RMBS and cash and synthetic CDO and CLO assets.
• Provident Bank in the repackaging of residuals from 10 mortgage deals on a synthetic basis.
• The Czech subsidiary of an Austrian financial services firm, Raiffeisen Bank, in connection with a synthetic securitization and credit-linked notes (CLNs) referencing its loan portfolio. The portfolio size was €1 billion with a related issue of €77 million CLNs by the bank’s securitization program.