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Agencies assess financial sector risks in Shared National Credit program report

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Industry Regulation, Inside the Beltway
Friday, March 1, 2024

Federal banking regulators released their 2023 Shared National Credit (SNC) report assessing credit quality and risk factors associated with large, syndicated bank loans as “moderate” despite some downward trends attributed to high interest rates. The SNC program analyzes industry developments among the largest and most complex credit facilities shared by regulated financial institutions and nonbank investors.

The program is governed by an interagency agreement among the Federal Reserve, the Federal Deposit Insurance Corp. (FDIC) and the Office of the Comptroller of the Currency (OCC).

The 2023 SNC portfolio included 6,589 borrowers, totaling $6.4 trillion in commitments – 8.7 percent higher than the previous year. The overall SNC population increased by $512 billion, or 8.7 percent year-over-year, with an increase of $438 billion in loans, which banks consider to be investment-grade loans. During that timeframe, outstanding balances increased by 7.3 percent alongside a 6 percent increase in borrowers and credit facilities throughout 2023.  

“The volume of leveraged transactions exhibiting layered risks increased significantly over the past several years, as strong investor demand for loans enabled borrowers to obtain less restrictive terms,” the agencies wrote in the report. “To date, the performance of these leveraged loans has not been tested through a typical economic cycle. The agencies continue to focus on assessing the impact of layered risks in leveraged lending transactions and the appropriateness of credit risk management practices in adapting to the changing environment.”

Risks in leveraged loans remain high, with specific industries like technology, telecom, media, healthcare, pharmaceuticals and transportation services facing elevated risks, the report indicates. The real estate and construction sectors show signs of segmented risk, with some sub-sectors observing deteriorating trends.

U.S. banks hold 46 percent of all SNC commitments but only 20 percent of non-pass loans, the report stated. Nearly half of all SNC commitments are leveraged, and leveraged loans account for 86 percent of non-pass loans.

Nonbank entities continue to participate in the leveraged lending market to earn returns from holding purchased credit exposure, the agencies explained in the report. These entities hold a disproportionate share of all loan commitments rated special mention or classified, compared to U.S. banks and foreign banking organizations (FBOs).

“These nonbank entities hold a significant portion of non-pass leveraged commitments and non-investment grade equivalent leveraged term loans,” the report stated. “By comparison, the SNC leveraged exposure held at banks is primarily comprised of investment-grade equivalent revolving credit facilities. However, the agencies note that these investment preferences are not universal as risk appetite varies among bank and nonbank participants.”

U.S. banks and FBOs held 78.9 percent of the total exposure, but only 35 percent of the non-pass exposure, the report continued. The special mention and classified rates at U.S. Banks and FBOs are 3.8 percent and 4.2 percent, respectively, while the special mention and classified rate at Nonbanks is 27.5 percent.

Despite challenges, industries affected by the pandemic, such as transportation and entertainment, demonstrate notable improvement, according to the report.

The agencies also noted positive developments in other industry segments with “greater vulnerability to rising interest rates and other macroeconomic factors,” including construction and real estate, as well as health care and pharmaceuticals; technology, telecom and media; and transportation services. The report states that these industries “showed high and/or increasing special mention and classified rates.” 
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