1. This article describes S&P Global Ratings' criteria for rating financial future flow securitizations—transactions whose repayment of principal and interest are secured by the generation of future diversified payment right (DPR) and merchant voucher (MV) receivables. DPR transactions are securitizations of international wire transfers, most commonly arising from export-related financing, foreign direct investment (FDI), portfolio investment, and remittances from citizens working abroad who send money back home. Securitizations of MVs represent financial obligations of credit card companies (e.g., VISA, MasterCard, and American Express) to pay back businesses or financial institutions for purchases and cash withdrawals made with foreign credit or debit cards. MV transactions rely heavily on tourism and business travel. We are publishing this article to consolidate previously published criteria articles, more clearly communicate criteria methodologies and assumptions, and help market participants better understand our approach to analyzing this asset class. This article is related to our criteria article "Principles of Credit Ratings," published on Feb. 16, 2011.

I. SCOPE OF THE CRITERIA

2. These criteria apply to all new and existing DPRs and MV financial future flow securitizations issued by banks rated by S&P Global Ratings. These criteria do not apply to corporate or public finance future flow securitizations.

II. SUMMARY OF CRITERIA

3. This paragraph has been deleted.

4. The criteria for rating financial future flow securities begins with the determination of the originating bank's potential issuer credit rating (ICR), as determined by "Financial Institutions Rating Methodology," published Dec. 9, 2021 (hereafter referred to as "FI criteria"). Nevertheless, as described in paragraph 14, no uplift will be afforded to transactions issued by institutions with "Low" likelihood of receiving extraordinary government support. In such cases, DPR and MV security ratings will be capped at the ICR of the originating bank.

5. Once the potential ICR has been established, the following structural features are then taken into account to determine any notches of elevation above the potential ICR: (1) stressed debt service coverage ratios (DSCRs); (2) transaction-adjusted bank liquidity; and (3) the stressed pay down period. The application of these factors will produce a structural assessment.

6. Additional structural features are reviewed on a pass/fail basis. The absence of any of the following attributes will limit the security rating to the ICR of the bank: (1) cash sharing mechanism (2) offshore lock box accounts (3) use of designated depository banks (DDBs) (4) Early amortization triggers (5) legal status of the assets.

7. The rating on the future flow security will be capped by the structural assessment and may be further adjusted downward according to the sovereign interference assessment (see Section D below).

8. Lastly, the rating on the security will be capped at three notches above the foreign currency ICR on the bank by these criteria. Separately, other criteria, such as "Incorporating Sovereign Risk In Rating Structured Finance Securities: Methodology And Assumptions," published Jan. 30, 2019, and "Global Framework For Assessing Operational Risk In Structured Finance Transactions," published Oct. 9, 2014, may also cap the security rating.

9. This paragraph has been deleted.

10. This paragraph has been deleted.

III. METHODOLOGY

11. These criteria provide a framework for assigning ratings to financial future flow transactions based on a multifaceted approach consisting of the (i) potential ICR for the originating bank, as per the FI criteria, (ii) a structural assessment, (iii) knock-out features, and (iv) a sovereign interference assessment. The potential ICR of the originating bank, which is responsible for generating the financial flows that support the structured transaction, is the starting point of the analysis. The structural assessment determines the number of notches, if any, a security can be rated above the potential ICR of the bank. Despite the outcome of the structural assessment, the absence of any of the knock-out features (see section C) will limit the transaction rating to the ICR of the bank. The final rating on the security may be constrained by the sovereign interference assessment, and is capped at three notches above the bank foreign currency ICR.

A. Potential ICR

12. The potential ICR of the bank will be used as a starting point for the rating of financial future flow transactions. Under the FI criteria, the methodology consists of two key steps: determining the bank's stand-alone credit profile (SACP), and assessing extraordinary government, group, guarantee, or additional loss-absorbing capacity (ALAC) support, to arrive at the potential ICR, which is a component of the ICR. The likelihood of extraordinary government support is, in turn, assessed either using the methodology for rating government-related entities (GREs) (see "Rating Government-Related Entities: Methodology And Assumptions," published March 25, 2015, hereafter referred to as "GRE criteria"), or, for assessing the likelihood of extraordinary government support due to systemic importance to the financial system, using the FI criteria. The latter assesses likelihood of government support depending on the level of a bank's systemic importance and a government's tendency to support a bank based upon this systemic importance; the GRE criteria assesses likelihood of government support considering the importance of the GRE's role to the government and the link between the GRE and the government.

13. Table 20 from the FI criteria categorizes the likelihood of future extraordinary government support as "High," "Moderately high," "Moderate," or "Low." Similarly, table 1 in the GRE criteria document categorizes the likelihood of future extraordinary support as "Almost certain," "Extremely high," or "Very high," in addition to the potential support categories that apply to banks based on systemic importance (i.e., "High," "Moderately high," "Moderate," or "Low"). The bank's potential ICR based on extraordinary government support results from adding notches for uplift to the SACP, using tables 20-23 of the FI criteria or tables 4-8 of the GRE criteria. In both cases, notches of support are added only in the case the support likelihood is "Moderate" or higher.

14. No uplift will be afforded to transactions issued by institutions with "Low" likelihood of receiving extraordinary government support. In such cases, DPR and MV security ratings will be capped at the originating bank's foreign currency ICR.

B. Structural Assessment

15. The structural assessment builds on the indicative ICR by evaluating the strength of the structural components of the proposed transaction. These characteristics allow future flow ratings to be higher than the potential ICR on the bank and are based on measurements of (1) cash flow modeling and DSCRs, (2) transaction-adjusted bank liquidity, and (3) transaction leverage. Factor (1) can add up to two notches to the potential ICR, while factors (2) and (3) can each add one notch to or subtract one notch from the potential ICR. For transactions with a target rating above the sovereign rating, these criteria should be applied in conjunction with "Incorporating Sovereign Risk In Rating Structured Finance Securities: Methodology And Assumptions," published Jan. 30, 2019.

1. Cash flow modeling and DSCRs

16. Cash flow analysis is a central element of the structured assessment. DSCR is the key metric used in the analysis and is measured as the amount of adjusted receivables in a given payment period divided by the largest debt service payment due throughout the life of the transaction.

17. Adjusted receivables are determined after taking into account the following:

• Base-case flow levels: Three years of historical data, accounting for potential seasonality, are used to determine the 12-month average cash flow for a DPR or merchant voucher transaction. To the extent that the cash flow represents a stable trend, the trailing 12 months of flows will instead be taken into account as an indicator of performance. If historical data demonstrates a declining trend, additional stresses are included to capture downside risk. No growth is assumed in the receivables over the life of the transaction.
• Interest rate and currency stresses: Interest rate stresses are applied for floating-rate securities that account for future interest rate fluctuations (see "CIR Model," published Oct. 18, 2019). Additionally, transactions that exhibit unhedged currency risk will be stressed to account for any asset liability mismatch (see "Foreign Exchange Risk In Structured Finance--Methodology And Assumptions," published April 21, 2017).
• Expenses: Anticipated transaction expenses are factored into our interest rate stress and typically range from 10-20 basis points (bps). Payment of extraordinary expenses should comply with "Global Framework For Payment Structure And Cash Flow Analysis Of Structured Finance Securities."
• Local flows: All local cash flow is excluded from our base-case flow levels. This category of flows typically consists of domestically generated payment orders associated with the offshore clearing and settlement of foreign currency funds among domestic financial institutions. Clearing and settling these transactions requires the participation of offshore foreign correspondent banks and ultimately creates DPR flows as offshore settlement payments are remitted back to a domestic recipient bank. Unlike international cash flows, local flows are generally not underpinned by true economic interactions with third-party entities in foreign jurisdictions, such as foreign businesses importing from, or investing in, a given country or migrant workers remitting funds from abroad. Given the potential impact of a change in local currency regulations (particularly the imposition of currency transfer and/or convertibility controls), all local collections are excluded when determining whether cash flow coverage is sufficient to satisfy DSC levels.
• Related party cash flow: Such flows are occasionally present in DPR transactions in which the originating bank is part of a larger conglomerate. Situations may arise where flow volumes generated by related entities may not represent true economic activities. In such instances, the criteria review the historical trend in flow volume generated between the originating bank and any related entities to determine if such flow volume should be removed.

18. Table 1 includes cash flow stresses by target rating category to be applied to the level of adjusted receivables determined above. Based on historical evidence (i.e., global financial crisis), the stresses, applied as haircuts, account for, among other risks, future changes in commodity prices, fluctuations in portfolio flows and foreign direct investment (FDI), worker remittances, and tourism and business travel. The 'BBB' stress represents the average of the largest decline in flows exhibited over time for all DPR and MV programs S&P Global Ratings rates. Stresses for the 'A' and 'BB' categories represent one standard deviation away from the mean, while stresses for the 'AA' and 'B' categories represent two standard deviations.

19. Higher levels of stress may be applied in cases where transactions exhibit large obligor concentration risks (see paragraphs 20-21). Cash flow stresses also assume the flows are well diversified by industry. Industry concentration risk is therefore also captured by applying an additional haircut to base-case cash flows (paragraph 22). For MV transactions, the criteria also consider risks from national disasters or world events that can directly affect the tourism and/or business travel industries of any relevant jurisdiction.

Table 1

Cash Flow Stress By Targeted Transaction Rating Category
	B	BB	BBB	A	AA
DPR and merchant voucher stress (%)	15	30	45	60	75
Note: Transactions are not eligible for 'AAA' ratings

20. These criteria assess a transaction's top 20 beneficiaries (i.e., the largest recipients of cash flow) in order to measure industry and customer concentration risks. If a particular beneficiary has many entities, the criteria look at the beneficiary at the consolidated level. In the case of transactions that exhibit domestic flows, the criteria generally concentrates only on the top 20 beneficiaries of international flows.

21. Risks associated with beneficiary concentration in investment-grade securities are captured by applying the higher of the applicable stress from table 1 and the concentration of the top 20 beneficiaries to the base-case receivables. For speculative-grade transactions, the higher of the concentration of the top 15 beneficiaries and the applicable cash flow stress from table 1 is applied to the base-case receivables. For example, if the targeted transaction rating is 'BBB' and the top beneficiaries make up 50% of the flows, then a discount factor of 50% would be applied to the adjusted receivables since this amount exceeds the 45% cash flow stress.

22. Industry risk for investment-grade transactions is captured by applying an additional haircut of up to 30% to the base-case receivables where (based on the top 20 beneficiaries) one industry or sector accounts for exposure of greater than 40% of the total annual DPR flows or two industries or sectors comprise greater than 60% of total annual flows (see tables 2 and 3). Industries are defined by the industry tables in S&P Global Ratings' CDO Evaluator (see "Global Methodology And Assumptions For CLOs And Corporate CDOs," published June 21, 2019).

Table 2

Industry/Sector Concentration (One Industry)
Haircut	Additional stress
Up to 40%	No additional stress
40%-55%	10% additional stress
55%-70%	20% additional stress
70%-85%	30% additional stress

Table 3

Industry/Sector Concentration (Two Industries)
Haircut	Additional stress
Up to 60%	No additional stress
60%-70%	10% additional stress
70%-80%	20% additional stress
80%-90%	30% additional stress

23. Table 4 represents DSCR thresholds rates for MV and DPR transactions. Such coverage levels are compared against stressed cash flows (adjusted receivables plus cash flow stress from table 1, while accounting for any obligor and/or industry concentrations), which include expectations of future volatility in cash flow generation. The levels of coverage directly translate into notches of elevation above the potential ICR.

Table 4

Debt Service Coverage Guidelines For DPR And MV Transactions
Stressed coverage ratios (x)	Number of notches above potential ICR
Up to 10x	0
10x-20x	1
20x and higher	2

24. Cash flow analysis is based on the lowest projected DSCR (after stress testing) over the term of the transaction. A transaction's DSCR may vary over time due to factors such as seasonality in the generation of receivables and a less-traditional amortization schedule. Cash flow modeling inputs for transactions with seasonality should correspond with the month or quarter in which they were generated to capture seasonal behavior.

2. Transaction-adjusted bank liquidity

25. Future flow transactions can strip away hard currency flows from a bank because they use payments due to domestic parties to pay debt service. While the inclusion of a cash sharing mechanism (see paragraph 29) mitigates this risk, it is still a factor, especially in a time of crisis. In general, leverage among future flow transactions is very low, given level amortization with seven- to 10-year maturity profiles. Nevertheless, the possible effects of such exposure on the bank are measured by the ratio of total outstanding financial future flow debt to the bank's core deposits.

26. Under the methodology, there is no impact on the transaction rating for leverage calculations of between 5% and 15% (see table 5). Above 15%, the methodology removes a one-notch uplift above the potential ICR, given the greater likelihood that during a crisis such measurements of adjusted liquidity would have a negative impact on bank operations. Banks with less than 5% of adjusted bank liquidity have programs that are eligible for an additional notch given the removed likelihood of any impact on bank operations.

Table 5

Transaction-Adjusted Bank Liquidity
Liquidity	Change in notches of elevation
Below 5%	1
Between 5%-15%	0
Above 15%	(1)

3. Stressed paydown period

27. While systemically important banks in jurisdictions benefitting from government intervention should survive selective default, the ability of a DPR or MV transaction to pay down quickly on an accelerated basis is a great strength to investors (for additional information, see "Diversified Payment Rights Put To The Test—A Kazakh Case Study," published July 21, 2010). This ability is measured in the number of days it would theoretically take to pay off the respective transaction program under an early amortization event. For such calculations, the stressed cash flows are applied given the likelihood that flow volumes would decrease under such a scenario. Typically, exceptionally strong programs are able to pay down over the course of a month, and moderately strong programs are able to pay off within two months. Higher leveraged programs tend to be able to pay off in more than three months. Such levels of leverage will affect the ratings elevation above the indicative ICR.

Table 6

Number Of Months To Pay Down Outstanding Debt
No. of months	Change in notches of elevation
0 to 1	1
Between 1 and 3	0
3 or more	(1)

C. Knock-Out Features

28. The absence of the following features will preclude a rating above the foreign currency ICR of the originating bank:

Cash sharing

29. A cash sharing mechanism ensures that a percentage of cash flow is returned to the bank during an accelerated amortization. This structural feature mitigates excessive liquidity strains on the bank that could result in the termination of the underlying business unit and/or the bank itself. Additionally, this feature limits a sovereign's incentive to interfere in the structure since a portion of hard currency cash flows, which can be critical to a sovereign, will be returned onshore.

Designated depository banks

30. DPR transactions incorporate the use of DDBs to reduce diversion risk to the transaction by allowing the majority of cash flow to be under the control of the transaction rather than that of the originating financial institution. DDBs generally comprise correspondent banks that receive at least 10% of the historical asset volume. The DDBs sign agreements that limit the remittance of cash flow back to the originating entity based on instruction from the transaction's trustee. For merchant voucher transactions, the relevant credit card company (e.g., VISA, MasterCard, and American Express) makes payments directly to offshore accounts.

Offshore lockbox accounts

31. Offshore transaction collection accounts greatly reduce the ability of the originator and the relevant government from interfering in the timely repayment of the transactions obligations. The direct payment of transaction cash flow into offshore collection accounts, coupled with the acknowledgement of third parties (i.e., DDBs and credit card companies), collectively governs the future transfer of the assets into the transaction accounts. This allows financial future flow transactions to potentially be rated above the relevant transfer and convertibility assessment (see "Criteria For Determining Transfer And Convertibility Assessments," published May 18, 2009) applicable to the bank's jurisdiction, subject to the sovereign interference assessment.

Early amortization triggers

32. Standard covenants linked to asset performance include acceleration triggers linked to declines in flow volume, minimum DSCRs, and a minimum percentage of cash flows captured by DDBs. Such covenants guard against a deterioration in asset volumes. Nonperformance triggers including those covering breaches of representations and warranties, bankruptcy of the originator and governmental interference, are also essential to the viability of financial future flow transactions.

Legal

33. In most cases, the isolation of the transaction's assets through a true sale to a SPV provides the legal basis for rating future flow transactions higher than an originator's other secured and unsecured obligations. In order to determine whether the transaction can be rated higher than the originator's foreign currency issuer credit rating, the legal status of the securitized assets is reviewed. The legal analysis of the transaction structure includes the receipt of legal opinions that provide comfort that the transaction's payment flow to the SPV would not be affected by the potential bankruptcy (or other similar proceeding) of the originator.

34. Irrespective of the form of asset transfer, both the specific legal provisions governing the transfer and the overall incentives for performance contained in the transaction are reviewed. Additional factors, such as the maturity and reliability of the legal system in which the transfer takes place and the ability of creditors to enforce their rights, will also be factored into the analysis. Also, for both types of transactions, S&P Global Ratings will review any notices, consents, and acknowledgements provided by the DDBs or credit card companies.

D. Sovereign Interference Assessment And Final Transaction Rating

35. Sovereign interference risk refers generally to the ability and propensity of a government to interfere in the proper functioning of a transaction. Such interference can be direct and undertaken with the specific intent to abrogate the terms of a transaction, or it may be indirect and affect a transaction as an unintended consequence of an unrelated government policy or regulatory action. A key part of a future flow rating includes, therefore, a review of the potential for government interference to affect the performance of a transaction.

Sovereign issuer credit ratings versus sovereign interference assessments

36. S&P Global Ratings does not regard sovereign credit ratings as necessarily definitive indicators of sovereign interference risk for the purpose of rating a structured finance transaction. Sovereign ratings are intended to convey S&P Global Ratings' opinion of the ability and willingness of a government to maintain full and timely payment on its own debt obligations. Sovereign interference assessments, however, are intended to measure a different type of risk: namely, the probability both that a government will attempt to interfere in the proper operation of a secured transaction (whether issued by a public or private entity) and that its attempt to do so will succeed. Official interference could come before, during, or after a sovereign default or could even occur in the absence of a government debt default altogether. Likewise, a debt default could occur without the government attempting to interfere in structured transactions at all. Because sovereign interference and sovereign default are not necessarily perfectly--or even highly--correlated in all circumstances, sovereign interference assessments can differ from sovereign issuer credit ratings.

37. It is also important to note that sovereign interference assessments can differ across transactions originated from the same country, as so much of the evaluation of interference risk is dependent on circumstances specific to each originator, the asset type, and the specific structural details of the transaction being rated. As a result, the ability and willingness of the government to interfere with these transactions could differ significantly.

38. Notwithstanding the imperfect correlation between government default and transaction interference, S&P Global Ratings does believe that there can be a connection between a government's financial condition and the incentive it has to attempt to interfere in a structured transaction. As a result, changes in a sovereign issuer credit rating can potentially lead to similar changes in a transaction interference assessment. These changes are not automatic, however, and depend on the interplay of a number of factors that are evaluated at the time of the change in the sovereign default rating.

Benefits versus costs of sovereign interference

39. S&P Global Ratings considers many factors when developing its views on the probability of sovereign interference (see Potential Factors Influencing a Sovereign Interference Assessment). One of the most important factors influencing the risk of interference is the incentive structure facing a government contemplating an attempt to interfere in a structured transaction. If successful, the maximum gain to the government from interfering would be a portion or potentially all of the debt service due on a transaction over the remaining term of the transaction. The gains to a government resulting from a successful intervention would include the receipt of foreign exchange earnings that would otherwise have been allocated to debt service on the transaction, the increased financial flexibility of the underlying borrower now freed from servicing the debt associated with the transaction, and, perhaps, certain political benefits associated with "standing up" to foreign creditors during a financially difficult period for a country. The financial gains would be magnified if the sovereign were to interfere successfully in a transaction already undergoing an early amortization or acceleration in which additional foreign exchange earnings were being allocated to repay debt service ahead of schedule. Moreover, the larger the aggregate debt service owed on future flow transactions undertaken by entities in a country, the greater the potential gain by a government considering an interference attempt (assuming it elected to interfere in all such transactions). S&P Global Ratings, therefore, tracks and evaluates future flow issuing activity by country as an aid in evaluating this incentive.

40. Balanced against this potential gain from interference, however, are the potential costs if the government attempts to interfere and fails to produce quickly the desired results. For example, if government interference is an early amortization or repurchase trigger in the transaction documentation (which it is in many rated deals), a failed attempt to interfere could leave the government worse off than if it had not tried to interfere at all. This is because the attempt itself could cause all generated receivables to be applied toward the early paydown of the transaction, with nothing flowing through to the originator or the originator's country until the transaction has been fully repaid. Thus, an interference attempt that failed could actually cost the country a great deal more in foreign exchange forgone than would be the case by simply allowing the originally scheduled debt service payments to be made. For some financial future flow deals (namely, those securitizing diversified payment rights), the high overcollateralization levels typically present in these transactions imply that the amount of funds that could be lost to an early paydown of the debt due to a failed interference attempt could be very significant and would likely far exceed the potential near-term gain from a successful attempt. An appeal by a sovereign to a court in the relevant jurisdiction (usually where the SPE is located) might temporarily or permanently allow some or all of the funds to flow back to the country, but for a government seeking a quick augmentation of its foreign exchange reserves in a time of financial stress, an attempt to divert funds owed to future flow investors would be an uncertain and potentially counterproductive way to achieve that goal.

Interference risk remains a significant rating factor

41. For each cross-border transaction rating, S&P Global Ratings assesses the rationale, including both incentives and disincentives, for a sovereign to interfere in the transaction.

42. The final rating on the security is anchored by the structural assessment and may be adjusted downward according to the sovereign interference assessment; it is also capped at three notches above the bank foreign currency ICR. Separately, the rating on the security may also be capped by other criteria, like "Incorporating Sovereign Risk In Rating Structured Finance Securities," published Jan. 30, 2019, or "Global Framework For Assessing Operational Risk In Structured Finance Transactions," published Oct. 9, 2014, to the originating bank as a Performance Key Transaction Party. See section "Expected Range Of Constraints For Sovereign Interference Assessment For A Diversified Payment Rights Transaction" below for further guidance on determining the sovereign interference risk.

E. Surveillance

43. The same methodology for assigning a rating to DPR or MV transactions is applied in the surveillance of DPRs and MV transactions. Surveillance of DPR and MV transactions begins with periodic surveillance reports received from the originating entity and/or the trustee. Periodic cash flows are monitored to determine if changes in DSCRs warrant a rating action. Concentration levels by obligors and industry are reviewed on an annual basis, along with leverage and liquidity.

44. Additionally, changes in the underlying bank SACP or our assessment of the likelihood of extraordinary government support would likely affect the potential ICR, and potentially the transaction rating. Any change in our view of sovereign interference risk could also affect the transaction rating.

Expected Range Of Constraints For Sovereign Interference Assessment For A Diversified Payment Rights Transaction

45. Depending on our assessment of the factors in the criteria, the analysis of the sovereign interference risk (SIR) may be either neutral or impose a constraint as compared with the maximum potential rating* for the transaction (the latter as per these criteria or "Incorporating Sovereign Risk In Rating Structured Finance Securities," published Jan. 30, 2019). The following example demonstrates the SIR analysis for financial future flow transactions:

• The SIR may be neutral for the transaction based on a combination of: 1) the sovereign's policy is generally open to foreign direct investment, with low negative interference in the financial sector and a track record of abiding by international court arbitrations; 2) the originator plays an important role for the economy--for example, has at least moderate likelihood of support--as per the FI group determination from GRE tables or the FI criteria tables; and 3) the specificity of the assets being securitized, and related structural protections, is such that redirection risk is relatively low. Where relevant, we consider any other factors cited in the two related criteria articles mentioned above. If neutral, the SIR indicates there is no incremental rating constraint beyond the maximum potential rating.
• The SIR may be high for the transaction if there is a history of significant negative sovereign interference in the sector (banks), asset class (redirecting foreign currency flows), or with the originator. If high, the SIR indicates that the rating is constrained at the issuer credit rating.
• The SIR may be moderate for the transaction--a determination between neutral and high. If moderate, the SIR indicates that the rating is constrained at least one notch below the maximum potential rating.

*The maximum potential rating for the transaction is defined by these criteria as a cap at three notches above the issuer credit rating on the bank, and by "Incorporating Sovereign Risk In Rating Structured Finance Securities" as a cap at two notches above the sovereign if the majority of assets backing the future flow securitization are considered to have high sensitivity to country risk (for example, foreign direct investment).

REVISIONS AND UPDATES

These criteria were published and became effective on Nov. 14, 2011.

Changes introduced after original publication:

• Following our periodic review completed on Nov. 13, 2015, we updated the contact information and references to criteria that have been superseded and removed paragraph 9, which was related to the initial publication of the criteria and therefore no longer relevant.
• Following our periodic review completed on Nov. 11, 2016, we clarified paragraph 3, updated criteria references, made minor editorial updates, and removed paragraph 10, which was related to the initial publication of the criteria and therefore no longer relevant. Lastly, we added the "Revisions And Updates" section.
• Following our periodic review completed on Nov. 10, 2017, we made clarifications in paragraphs 8, 35, and 36 and added paragraph 39 (all of these with respect to the interrelation with other criteria). We clarified tables 5 and 6, updated related criteria references, and made other minor editorial updates.
• On Jan. 9, 2019, we republished this criteria article to make nonmaterial changes to the contact information.
• On Oct. 31, 2019, we republished this criteria article to make nonmaterial changes to certain criteria references.
• On Jan. 17, 2020, we republished this criteria article to make nonmaterial changes. We incorporated the "Sovereign Interference Risk Assessment" section from "The Three Building Blocks Of An Emerging Markets Future Flow Transaction Rating," published Nov. 16, 2004. The material that was moved had already been part of these criteria by way of a reference; in moving it, we consolidated the material, which did not materially change, and removed the reference. In addition, we updated language in paragraphs 7, 11, and 42 to clarify that the final rating on the security is anchored by the structural assessment and may be adjusted downward according to the sovereign interference assessment. We also updated various criteria references.
• On Nov. 2, 2020, we republished this criteria article to make nonmaterial changes to certain criteria references.
• On July 8, 2021, we republished this criteria article to make nonmaterial changes to update criteria references.
• On July 8, 2022, we republished this criteria article to make nonmaterial changes to update contact details and related research.
• On June 20, 2023, we republished this criteria article to make nonmaterial changes to update cross-references to the FI criteria.
• On Sept. 20, 2024, we republished this criteria article to make nonmaterial changes to update terminology to be consistent with that found in "Financial Institutions Rating Methodology," Dec. 9, 2021. Additionally, we removed outdated criteria and research references.

RELATED PUBLICATIONS

Related criteria

• Financial Institutions Rating Methodology, Dec. 9, 2021
• Global Framework For Payment Structure And Cash Flow Analysis Of Structured Finance Securities, Dec. 22, 2020
• Global Methodology And Assumptions For CLOs And Corporate CDOs, June 21, 2019
• Counterparty Risk Framework: Methodology And Assumptions, March 8, 2019
• Incorporating Sovereign Risk In Rating Structured Finance Securities: Methodology And Assumptions, Jan. 30, 2019
• Foreign Exchange Risk In Structured Finance--Methodology And Assumptions, April 21, 2017
• Rating Government-Related Entities: Methodology And Assumptions, March 25, 2015
• Global Framework For Assessing Operational Risk In Structured Finance Transactions, Oct. 9, 2014
• Criteria For Determining Transfer And Convertibility Assessments, May 18, 2009

Related research

• Credit FAQ: Recent Trends in Latin American DPR Transactions, April 18, 2016
• Diversified Payment Rights Put to The Test—A Kazakh Case Study, July 21, 2010
• Scenario Analysis: Emerging Market Financial Future Flow Securitizations Should Weather Upsets, Both At Home And Abroad, Aug. 5, 2008

Analytical Contacts:	Antonio Zellek, CFA, Mexico City + 52 55 5081 4484; antonio.zellek@spglobal.com
	Leandro C Albuquerque, New York; leandro.albuquerque@spglobal.com
Methodology Contact:	Eric Gretch, New York 1-347-229-7103; eric.gretch@spglobal.com