0000891092-16-014024.txt : 20160407 0000891092-16-014024.hdr.sgml : 20160407 20160407172328 ACCESSION NUMBER: 0000891092-16-014024 CONFORMED SUBMISSION TYPE: ABS-15G PUBLIC DOCUMENT COUNT: 3 CONFORMED PERIOD OF REPORT: 20160407 0001671571 ITEM INFORMATION: 2.01 FILED AS OF DATE: 20160407 DATE AS OF CHANGE: 20160407 RULE-15GA2 N Student loans 0001671638 CB DEPOSITOR 2016-A SPV, LLC FILER: COMPANY DATA: COMPANY CONFORMED NAME: CB Depositor 2016-A SPV, LLC CENTRAL INDEX KEY: 0001671571 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: ABS-15G SEC ACT: SEC FILE NUMBER: 025-02735 FILM NUMBER: 161560839 BUSINESS ADDRESS: STREET 1: 524 BROADWAY STREET 2: 6TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10012 BUSINESS PHONE: 800-975-7812 MAIL ADDRESS: STREET 1: 524 BROADWAY STREET 2: 6TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10012 ABS-15G 1 e69003_abs15g.htm FORM ABS-15G

OMB Number: 3235-0675

 

 

 

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM ABS-15G

ASSET-BACKED SECURITIZER
REPORT PURSUANT TO SECTION 15G OF
THE SECURITIES EXCHANGE ACT OF 1934

CB DEPOSITOR 2016-A SPV, LLC

 

Check the appropriate box to indicate the filing obligation to which this form is intended to satisfy:

____Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period______________ to _________________
Date of Report (Date of filing) __________________
Commission File Number of securitizer: __________________
Central Index Key Number of securitizer:__________________

 

  

 

Name and telephone number, including area code, of the person
to contact in connection with this filing.

Indicate by check mark whether the securitizer has no activity to report for the initial period pursuant to Rule 15Ga-1(c)(l) [ ]
Indicate by check mark whether the securitizer has no activity to report for the quarterly period pursuant to Rule 15Ga-1(c)(2)(i) [ ]
Indicate by check mark whether the securitizer has no activity to report for the annual period pursuant to Rule 15Ga-1(c)(2)(ii) [ ]
XRule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)
Central Index Key Number of depositor: 0001671571

        CB DEPOSITOR 2016-A SPV, LLC        
(Exact name of issuing entity as specified in its charter)

Central Index Key Number of issuing entity (if applicable): 0001671638
Central Index Key Number of underwriter (if applicable):  Not applicable              
Morgan Edwards, (203) 273-7370

Name and telephone number, including area code, of the person
to contact in connection with this filing.

 
 

FINDINGS AND CONCLUSIONS OF THIRD-PARTY DUE DILIGENCE REPORTS

 

Item 2.01 Findings and Conclusions of a Third Party Due Diligence Report Obtained by the Issuer

The disclosures required by Rule 15Ga-2 (17 CFR 240.15Ga-2) are attached an Exhibit to this Form ABS-15G. Please see the Exhibit Index for the related information.

 

 
 

 

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the reporting entity has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

    CB DEPOSITOR 2016-A SPV, LLC
       
       
Date: April 7, 2016 By:                /s/ T. Morgan Edwards II                     
    Name: T. Morgan Edwards II
    Title: Chief Financial Officer

 

 
 

 

 

EXHIBIT INDEX

 

 

Exhibit Number

 

99.1 Deloitte & Touche LLP Agreed-Upon Procedures Letter

 

 

 

 

 

 

EX-99.1 2 e69003ex99-1.htm DELOITTE & TOUCHE LLP AGREED-UPON PROCEDURES LETTER

Exhibit 99.1

 

 
 
 
Deloitte & Touche LLP
Suite 400
Harborside Plaza 10
Jersey City, NJ 07311
USA


Tel:   +1 212 937 8200
Fax:  +1 212 937 8298
www.deloitte.com

April 5, 2016

 

CommonBond, Inc.
524 Broadway, 6th Floor
New York, New York 10013

 

Independent Accountants’ Report

on Applying Agreed-Upon Procedures

 

 

Ladies and Gentlemen:

 

We have performed the procedures described below, which were agreed to by CommonBond, Inc. (the “Company”) and Barclays Capital Inc. (the “Other Specified Party” and, together with the Company, the “Specified Parties”), related to their evaluation of certain information with respect to a portfolio of student loans in connection with the proposed offering of CommonBond Student Loan Trust 2016-A, Private Credit Student Loan-Backed Notes (the “Transaction”).

 

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of the Specified Parties of this report. Consequently, we make no representations regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

 

Agreed-Upon Procedures

 

On March 22, 2016, representatives the Company provided us with a computer-generated student loan data file and related record layout containing, as represented to us by the Company, data as of March 16, 2016, with respect to 2,398 student loans (the “Initial Statistical Loan File”). Further, on March 27, 2016 representatives of the Company provided us with a supplemental student loan data file containing “borrower name” and “amount of last payment” information for each of the 2,398 student loans set forth on the Initial Statistical Loan File (the “Supplemental Loan File”).

 

Representatives of the Company instructed us to append the Initial Statistical Loan File with the information set forth on the Supplemental Loan File. The Initial Statistical Loan File, as adjusted, is herein referred to as the “Statistical Loan File.”

 

At your instruction, we randomly selected 100 student loans (the “Sample Loans”) from the Statistical Loan File and performed certain comparisons and recomputations for each of the Sample Loans relating to the student loan characteristics (the “Characteristics”) set forth on the Statistical Loan File and indicated below.

 
 

Characteristics

1.      Loan number (for informational purposes)

2.      Loan type (In-school, Refinance)

3.      Borrower name

4.      Borrower state

5.      Original loan balance

6.      Deferment end date (if applicable)

7.      Forbearance end date (if applicable)

8.      Amount of last payment

9.      First disbursement date

10.  Loan status

11.  Current interest rate

 

12.        Current loan balance

13.        Repayment begin date

14.        Repayment end date

15.        Borrower credit score

16.        Co-borrower credit score (if applicable)

17.        Credit score

18.        Borrower income

19.        School

20.        Graduation year

21.        Borrower degree program

 

 

We compared Characteristics 2. and 3. (as set forth on the Statistical Loan File) to the corresponding information set forth on or derived from the Promissory Note or Approval Disclosure Statement (collectively, the “Originating Documents”) and to an electronic loan file, prepared, created, and delivered by the Company to us on March 31, 2016, from the Company’s servicing system as of March 16, 2016 (the “Servicer System File”); Characteristics 4. through 14. to the Servicer System File; Characteristics 15. through 17. to the “Credit Report;” Characteristic 18. to a borrower’s pay stub, borrower’s W-2 or other related correspondence (collectively, the “Income Verification Documentation”) and Characteristics 19. through 21. to the Degree Verified Certificate, or other related correspondence (collectively, the “Degree Verification Form”).

 

At your instruction, for purposes of our comparisons:

 

·with respect to our comparison of Characteristic 2., a loan type of (i) “refinance” as set forth on the Statistical Loan File is noted to be in agreement with “consolidation” as set forth on the Originating Documents and (ii) “in-school” as set forth on the Statistical Loan File is noted to be in agreement with “private education” as set forth on the Originating Documents. Further, a loan type of (i) “refinance” as set forth on the Statistical Loan File is noted to be in agreement with “CBGRL” or “CBHBRD” as set forth on the Servicer System File and (ii) “in-school” as set forth on the Statistical Loan File is noted to be in agreement with “CBMBA” and as set forth on the Servicer System File.

 

·with respect to our comparison of Characteristic 5., for those Sample Loans indicated to be “in-school” as set forth on the Statistical Loan File, we were instructed to multiply the original loan balance as set forth on the Servicer System File by 102% and compare such recomputed amount. Such comparisons were found to be in agreement;

 

·with respect to our comparison of Characteristic 17., if a borrower and co-borrower credit score were observed on the Credit Report, we compared the higher score; and

 

·with respect to our comparison of Characteristic 18., differences of 2.5% or less of the borrower income amount indicated on the Statistical Loan File are noted to be in agreement;

 

The student loan documents (including the Servicer System File) described above and any other related documents used in support of the Characteristics were provided to us by representatives of the Company and are collectively referred to hereinafter as the “Loan Documents.” We were not requested to perform, and we did not perform, any procedures with respect to the preparation or verification of any of the information set forth on the Loan Documents and we make no representations concerning the accuracy or completeness of any of the information contained therein. In certain instances, procedures were performed using data imaged facsimiles or photocopies of the Loan Documents. In addition, we make no representations as to whether the Loan Documents are comprehensive or valid instruments or reflect the current prevailing terms with respect to the corresponding Sample Loans.

 

  Member of
  Deloitte Touche Tohmatsu Limited

 

 

 
 

Agreed-Upon Procedures’ Findings

The results of the foregoing procedures indicated that the Characteristics set forth on the Statistical Loan File were found to be in agreement with the above mentioned Loan Documents, except as described in Appendix A. Supplemental information is contained on Appendix B.

 

******

 

We make no representations as to the (i) actual characteristics or existence of the underlying documents or data comprising the student loans underlying the Statistical Loan File or the conformity of their characteristics with those assumed for purposes of the procedures described herein, (ii) existence or ownership of the student loans or (iii) reasonableness of any of the aforementioned assumptions, information or methodologies.

 

It should be understood that we make no representations as to questions of legal interpretation or as to the sufficiency for your purposes of the procedures enumerated in the preceding paragraphs. Also, such procedures would not necessarily reveal any material misstatement of the information referred to above. The information provided to us, including the information set forth in the Statistical Loan File, is the responsibility of the Company.

 

We were not engaged to conduct, and did not conduct, (i) an audit conducted in accordance with generally accepted auditing standards or (ii) an examination or a review conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants, the objective of which would be the expression of an opinion or limited assurance on the accompanying information. Accordingly, we do not express such an opinion, limited assurance, or any other form of assurance, including reasonable assurance. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. We have no responsibility to update this report for events or circumstances occurring after the date of this report.

 

None of the engagement, procedures or report was intended to address, nor did they address, the (i) conformity of the origination of the assets to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) value of collateral securing such assets or (iii) compliance of the originator of the assets with federal, state, and local laws and regulations.

 

None of the engagement, procedures or report were intended to satisfy, nor did they satisfy, any criteria for due diligence published by a nationally recognized statistical rating organization.

 

This report is intended solely for the information and use of the Specified Parties identified above and is not intended to be and should not be used by anyone other than these Specified Parties.

 

 

Yours truly,

 

 

 

 
 

Appendix A to Independent Accountants’ Report on Applying Agreed-Upon Procedures issued by Deloitte & Touche LLP dated April 5, 2016. In applying our agreed-upon procedures as outlined above, we noted the following:

 

Exception Description Number

 

 

Exception Description

   
1 Three difference in School.
2 Five differences in Graduation year
3 Three differences in Borrower degree program
4 Two differences in Borrower income

 

 

 

The information above reflects the procedures performed and is subject to the conditions set forth in the agreed-upon procedures report to which this appendix is attached.

 
 

Appendix B to Independent Accountants’ Report on Applying Agreed-Upon Procedures issued by Deloitte & Touche LLP dated April 5, 2016

 

Supplemental Information Related to the Findings Set Forth on Appendix A

 

 

 

 

Exception Description Number

 

Sample Loan number

 

 

 

Characteristic

 

Characteristic set forth on the Statistical Loan File

 

Characteristic set forth on the Degree Verification Form

         
1 2235840000L0XS425 School University of the Incarnate Word North Carolina School of the Arts
1 2235840000L1H843C School Saint Mary’s University Texas A&M University – Corpus Christi
1 2235840000L20O44B School Palo Alto University Ohio Northern University
2 2235840000L1K043O Graduation Year 2016 2011
2 2235840000LOE73IH Graduation Year 2014 2013
2 2235840000LPPF3OF Graduation Year 1983 1980
2 2235840000LQH73S5 Graduation Year 2015 2011
2 9000030000L1MS006 Graduation Year 2014 2015
3 9000030000L2PO00H Borrower degree program Masters Bachelors
3 9000030000L290002 Borrower Degree program Masters Bachelors
3 9000030000L29000A Borrower Degree program Masters Bachelors

 

 

Exception Description Number

 

Sample Loan number

 

 

 

Characteristic

 

Characteristic set forth on the Statistical Loan File

 

Characteristic set forth on the Income Verification Documentation

         
4 2235840000LNBB3EC Borrower Income $5,000.00 $4,812.52
4 2235840000LRBR3WK Borrower Income $5,583.00 $9,284.65

 

 

The information above reflects the procedures performed and is subject to the conditions set forth in the agreed-upon procedures report to which this appendix is attached.

 

 

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