DBRS Morningstar Assigns Provisional Ratings of AAA (sf), A (high) (sf), and BBB (sf) to CARDS II Trust, Series 2022-2

DBRS Limited (DBRS Morningstar) assigned provisional ratings to the Credit Card Receivables-Backed Notes, Series 2022-2 (the Notes) to be issued by CARDS II Trust (the Trust) as follows:

-- AAA (sf) to the Credit Card Receivables-Backed Class A Notes, Series 2022-2 (the Class A Notes)
-- A (high) (sf) to the Credit Card Receivables-Backed Class B Notes, Series 2022-2 (the Class B Notes)
-- BBB (sf) to the Credit Card Receivables-Backed Class C Notes, Series 2022-2 (the Class C Notes)

The Notes are expected to be denominated in U.S. dollars. Cross-currency swaps are expected to be in place for the Notes.

The finalization of the ratings is contingent upon receipt of final documents conforming to information already received by DBRS Morningstar.

DBRS Morningstar considered the following factors in its analysis:

(1) For the Class A Notes, credit enhancement (CE) will be available through subordination of 7.25% (4.25% Class B Notes and 3.00% Class C Notes), excess spread, and the series-specific cash reserve account, which could build up to 5% of the initial invested amount.

(2) For the Class B Notes, CE will be provided by subordination of 3.00% (the Class C Notes), excess spread, and the series-specific cash reserve account.

(3) For the Class C Notes, CE will be available through excess spread and the series-specific cash reserve account.

(4) Three-month average payment rates and gross yield remain strong, averaging more than 43% and 22%, respectively, over the past three years. Prior to the pandemic, three-month average losses averaged 3.2% over the previous three years. Three-month average losses remain lower going into 2022 compared with pre-pandemic loss rates and stand at 1.2% as of February 28, 2022. The overall performance of the portfolio has been strong and is trending better than historical levels prior to the Coronavirus Disease pandemic.

(5) The receivables pool is a well-diversified, seasoned portfolio and is one of the largest in Canada.

DBRS Morningstar stress testing indicates that simultaneous declines in yield and payment rates and increases in losses would not result in a failure of the Trust in repaying the Notes on a timely basis. The severity of the tests applied is commensurate with the respective ratings of the Notes.

DBRS Morningstar’s analysis also indicates that the Class B Notes are expected to withstand more punitive stress multiples for requested rating categories, warranting a (high) designation and resulting in an A (high) (sf) rating.

DBRS Morningstar notes that the program fees and expenses (which could include indemnity payments) that are payable to the financial services agent are not subordinated to payments to Noteholders, as expected in DBRS Morningstar’s “Legal Criteria for Canadian Structured Finance.” DBRS Morningstar will monitor the monthly servicer reports and, to the extent that these fees and expenses may affect payments to Noteholders, DBRS Morningstar will review and take appropriate rating actions, if necessary.

DBRS Morningstar also notes that a true sale opinion in respect of the co-ownership interests in any accounts that may be added may not be delivered at the time of each account addition, as expected in DBRS Morningstar’s “Legal Criteria for Canadian Structured Finance.” DBRS Morningstar considers the risk minimal as additional accounts are transferred to the Custodian infrequently, an officer’s certificate is provided by the Seller in connection with each additional account transfer, and a true sale opinion in respect of the co-ownership interests in any accounts that may be added will be delivered every six months for any additions made within the previous six months.

There was no Environmental, Social or Governance factors or consideration with a significant or relevant impact on the credit rating.

A description of how DBRS Morningstar considers ESG factors within the DBRS Morningstar analytical framework can be found in the DBRS Morningstar Criteria: Approach to Environmental, Social, and Governance Risk Factors in Credit Ratings at https://www.dbrsmorningstar.com/research/373262.

Notes:
All figures are in Canadian dollars unless otherwise noted.

The principal methodology is Rating Canadian Credit Card and Personal Line of Credit Securitizations (November 1, 2021), which can be found on dbrsmorningstar.com under Methodologies & Criteria.

The DBRS Morningstar Sovereign group releases baseline macroeconomic scenarios for rated sovereigns. DBRS Morningstar analysis considered impacts consistent with the baseline scenarios as set forth in the following report: https://www.dbrsmorningstar.com/research/384482.

The related regulatory disclosures pursuant to the National Instrument 25-101 Designated Rating Organizations are hereby incorporated by reference and can be found by clicking on the link under Related Documents or by contacting us at info@dbrsmorningstar.com.

The Trust or Canadian Imperial Bank of Commerce, in its capacity as Financial Services Agent of the Trust, participated in the rating process. DBRS Morningstar had access to the accounts and other relevant internal documents of the Trust or the Financial Services Agent.

Please see the related appendix for additional information regarding the sensitivity of assumptions used in the rating process.

The full report providing additional analytical detail is available by clicking on the link under Related Research below or by contacting us at info@dbrsmorningstar.com.

For more information on this credit or on this industry, visit www.dbrsmorningstar.com or contact us at info@dbrsmorningstar.com.

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