Exploring The Impact Of Proposed Changes Finance Essay

The recent fiscal crisis exposed a assortment of failings in the securitization markets. The ordinance of asset-backed securities, Regulation AB, proved to be uneffective as it did non supply investors with sufficient information to do knowing investing determinations. Due to the high hazard of the assets underlying these securities, investor fright rose dramatically taking to the backdown of financess and inaction in the market. In response to this, the SEC late issued a proposal bill of exchange to assist regenerate demand through enhanced revelations and more efficient hazard allotment. The four alterations discussed in this paper include: 1 ) loan-level informations, 2 ) computing machine waterfall plan, 3 ) hazard keeping, and 4 ) CEO enfranchisement. Through empirical analysis, it is apparent that these four commissariats will hold a positive consequence on ABS markets by increasing transparence and re-allocating the hazard of loss.

1. Introduction

1.1 Background and Research Question

Securitization was originally used by Bankss to assist finance the mortgage market. As its ability to widen recognition was realized, securitization shortly hit about every sector of the economic system, including the car, consumer recognition, and existent estate industries, amounting to over $ 10 trillion outstanding by 2008.[ 1 ]However, as this market continued to spread out at rapid rates, jobs arose with respects to the construction of the minutess. Harmonizing to SEC Chairman Mary Shapiro, “ sound underwriting patterns inaˆ¦the ABS market took a back place to immediate net incomes. ” The market shortly became characterized by hapless loaning patterns and, due to the insufficiency of ordinance, loaners continued to “ switch their hazard of loss to investors. ”[ 2 ]As the fiscal crisis loomed, ABS holders suffered significant losingss, taking to backdown of financess and inaction in the market.[ 3 ]

The ordinance and revelation demands “ for publically issued asset-backed securities ( ABS ) were originally governed by the Securities Act of 1933 and the Exchange Act of 1934. ” Due to the alone and complex features of the modern securitization market, the Securities and Exchange Commission ( SEC ) has continually revised ABS ordinance to better run into the demands of market participants.[ 4 ]On December 22, 2004, the SEC issued the concluding bill of exchange of Regulation AB. These new regulations updated the Securities Act enrollment demands and provided coverage counsel for filings affecting ABS,[ 5 ]including enhanced revelations of patrons, plus pools, conceivers, and recognition sweetenings. However, the recent prostration of the securitization market proved Regulation AB ineffective. In visible radiation of this, the SEC has proposed important alterations to these regulations in an effort to “ better investor protection and advance more efficient asset-backed markets. ”[ 6 ]The major alterations that are discussed in this paper include ( pwc.com ) :

Disclosure Revisions:

Standardized Loan-level Datas: Regulation AB requires implicit in plus information merely at the pool degree. The proposal includes a demand for patrons “ to supply specific informations revelations for each loan in the plus pool ” at the beginning and on an on-going footing.

SEC Computer Model for Analyzing Securities: Under current regulations, merely a qualitative description of the ABS waterfall is disclosed in the prospectus. The SEC has proposed that each dealing include “ a computing machine plan that demonstrates the consequence of the waterfall. ”

Registration Revisions – Presently, ABS offerings are non eligible for expedited enrollment “ unless the securities are rated investing class by a recognition evaluation bureau. ” Due to the undependability and inaccuracy of these evaluations in the ABS market, the SEC is sing new shelf eligibility standards, which are stated below.

Issuer CEO Certification: The CEO of the issuer must attest that it is sensible that the assets in the pool “ will bring forth hard currency flows as described in the prospectus. ”

5 % Skin in the Game: The patron, instead than conceiver of the loan, must keep a maintained involvement of at least 5 per centum of each tranche. They are besides disallowed from economically fudging these involvements.[ 7 ]

1.2 Research Method

The research methods will include the usage of the official SEC Proposal and related remarks by industry professionals. I will besides analyze and analyze existing literature, including accounting databases, diaries, and articles related to the asset-backed securities market that could offer possible penetration into this research inquiry. For my empirical analysis, I will analyse SEC filings and revelations related to asset-backed securities and demo how investors were misled due to insufficiency and non-transparency. I will so explicate how these new commissariats will impact the securitization market by leveraging old revelations and calculating future revelations.

1.3 Main Findingss

The chief findings show that the proposed alterations will be good to the ABS market because the new ordinance will assist investors go more cognizant of the true value and hazard of their investings. Through empirical analysis, the alterations help to get the better of the defects of Regulation AB by advancing sound underwriting schemes and safer investing merchandises through enhanced revelation and enrollment demands.

1.4 Academic and Societal Relevance

This research subject is highly relevant to the hereafter of the securitization market. These proposed regulations will assist to bridge the information spread between investor and conceiver, aid reconstruct unity in the market, and regenerate the demand for these securities. This will assist to increase the handiness of recognition and reconstruct the strength of fiscal markets as a whole.

1.5 Outline of Thesis

In chapter 2, the research inquiry and bing literature are discussed. In chapter 3, I discuss the motive for and description of the research methodological analysis, every bit good as the informations retrieval procedure. My empirical findings are illustrated in Chapter 4. Finally, Chapter 5 concludes with a sum-up of the research, presentation of chief decisions, and treatment of thoughts for farther research.


2.1 Research Question

The recent fiscal crisis “ highlighted a figure of concerns with the operation of the regulations in the securitization market. ”[ 8 ]Harmonizing to the SEC, investors and other market participants “ did non hold the necessary tools to be able to to the full understand the hazard and value of the securities. ”[ 9 ]To assist rectify these jobs, the SEC issued a proposal on April 7, 2010 that offered important alterations to the enrollment and coverage demands for asset-backed securities. The proposed regulations are “ intended to better protect investors in the securitization market by giving them more elaborate information about the assets that are pooled into ABS, more clip to do their investing determination, and the benefits of better alining the involvements of issuers and investors. ”[ 10 ]In this paper, I will research and analyse the impact of these four proposed alterations on the issue of plus backed securities and transparence of company revelations, with a focal point on information dissymmetry and misalignment of inducements between investor and conceiver.

2.2 Existing Literature

The proposal bill of exchange is presently in its 90-day remark period and there has been much argument sing the effects of these commissariats. For my empirical informations, I will utilize the proposal remarks written by industry professionals, which are posted on the SEC web site, every bit good as a assortment of databases and articles sing this subject. Although there is a broad array of beginnings with many differing positions, I have decided to utilize the bulk point of views as a footing for my statement.

In respects to disclosure, many statements are in favour of loan-level statistics, but against the SEC computing machine theoretical account. Many professionals feel that loan-level informations, as opposed to aggregated inactive pool informations, will increase transparence sing the value and hazards of the assets, whereas the standardised computing machine theoretical account will be inefficient due to its complications and susceptibleness to error. With regard to the enrollment commissariats, industry experts agree that necessitating issuer CEO enfranchisement would guarantee higher loan quality by puting more duty on the issuer. However, some believe that 5 % hazard keeping will expose fiscal establishments to excessively much hazard.

In my analysis, I will demo how each proposed alteration to Regulation AB will profit the securitization market with a focal point on how it bridges the information spread between conceiver and investor and allocates the hazard of loss more suitably. Through the usage of empirical informations, I will re-affirm the statements in favour of the alterations and rebut the statements in resistance to the alterations. I will besides offer farther penetration into this subject by urging extra alterations that could assist to rejuvenate the market.


3.1 Motivation for Research Method Applied

My research methodological analysis aims to supply an apprehension of the types of information investors antecedently had entree to under Regulation AB and how the new alterations will do revelations more accessible and better reflect the value of the securities. The methods used will besides assist to show how the new alterations will break apportion the hazard of loss between conceiver and investor.

3.2 Description of Research Method

The chief subject of the thesis is to research the effects of the SEC proposal on the asset-backed securities market. In order to make my nonsubjective, I conduct an empirical analysis utilizing both primary and secondary informations. Primary informations includes the SEC Proposal, related remarks, and specific SEC disclosures to demo how implicit in plus information was unequal to stand for the true value and hazard of the invested securities. Secondary informations includes bing literature to show how the new enrollment demands will assist to re-allocate some of the fiscal hazard from investor back to the conceiver. I will besides utilize this secondary information to assist help me in calculating future revelations, every bit good as urging extra alterations that could besides revamp the ABS market.

3.3 Data Retrieval Process

In order to take which companies to analyse, I researched the major participants in the securitization market. Harmonizing to Asset-Backed Alert, JPMorgan Chase ( JPM ) and Citigroup ( C ) have clearly dominated the market with new issues of “ $ 62.8 billion and $ 41 billion in the securities, severally, ” over the past twelvemonth.[ 11 ]Due to handiness of informations, I decided to analyse the ABS revelations of JPMorgan Chase with regard to its Automobile Loans.

For the two revelation alterations, I use the Prospectus and Static Pool informations of the Chase Auto Owners Trust, specifically 2006-A, since it is the most recent available. These statistics can be found on the JPMorgan Chase website under Asset-backed Securities in the Investor Relations subdivision. I besides attempt to exemplify the presentation and format of the new revelations under the proposed coverage demands. This scheme will assist to foster picture the good effects of these alterations – “ to supply investors with more informations to independently measure the hazard ” of the securities and do better informed determinations.[ 12 ]For the enrollment alterations, I analyze bing literature to assist back up my statement. This includes the SEC proposal and related remark letters, articles written by industry professionals, and internal accounting paperss. I besides use the foundation of my research to offer extra alterations that could reconstruct the market.

4. Analysis OF FINDINGS

4.1 Standardized Loan-level Data

Under Regulation AB, as drafted in December of 2004, issuers of asset-backed securities merely have to unwrap inactive pool degree information of the implicit in assets on the company websites in PDF format. As shown below for the Chase Auto Owner Trusts, these revelations include statistics, such as the Aggregate Principal Balance, Weight Average Footings, and FICO tonss, to call a few.

Table 4.1 Inactive Pool Data

Beginning: JPMorgan.com

Other revelations provided by issuers to investors include delinquency agendas, pool balances, and ABS velocities. As evidenced by the inactive pool revelation above, ABS investors are clearly non given adequate information to do an educated investing determination. Although an aggregative statistical presentation does “ ease an investor ‘s apprehension of the overall investing chance, ”[ 13 ]it does non provide them with the specific information needed to decently measure the hazard and value of the single securities underlying their investings. For illustration, if the default rate of the plus pool rose and the aggregative outstanding chief balance, in consequence, fell, it would be highly hard for investors to find how this alteration would impact their single investings. Furthermore, the usage of the Portable Document Format ( PDF ) presents even more of a challenge to investors, since they are non able to set the statistics and re-analyze their investings on an on-going footing.

In response to these informational barriers, the SEC has proposed that patrons provide specific revelations for “ each loan in the plus pool both at the clip of issue and on an on-going footing. ” The loan-level “ Asset Data File ” would include several standardized informations points divided into two classs:

General informations, such as the footings, subventioning standards, and borrower recognition information, and

Asset type-specific informations, such as the features of the collateral procuring the loan. These extra informations include:

RMBS – 151 informations points

CMBS – 47 informations points

Car leases – 9 points

Equipment leases – 5 points

Student loans – 6 informations points[ 14 ]

The regulations besides require that the information be tagged in extensile Markup Language ( XML ) and filed on EDGAR so that it can be easy downloaded and adjusted. This would heighten handiness every bit good as facilitate informations and public presentation analysis by investors.[ 15 ]

Since the release of this proposal on April 7, 2010, many industry professionals have publicized their sentiment with respects to this new revelation demand. While most agree that the “ Asset Data File ” will assist bridge the information spread between investor and issuer, some feel that it crosses the boundaries of confidentiality. During the SEC meeting, two commissioners instantly expressed concerns that this new revelation would non to the full protect the personal information of single borrowers.[ 16 ]Popular positions have even gone far plenty to reason that this new demand would “ stand for fraud in the offer and sale of securities. ” In his remark missive to the SEC, Daniel Edstrom claims that “ the use of our personally identifiable information in the offer and sale of securities without our EXPRESS WRITTEN PERMISSION is individuality larceny. ”[ 17 ]

In visible radiation of these concerns, the SEC has proposed that certain plus degree information be provided in a coded response to protect the privateness and individuality of borrowers. For illustration, “ recognition tonss would be provided in a scope ” instead than stipulating the exact figure, and geographical country would be represented by Metropolitan Statistical Area alternatively of the nothing codification.[ 18 ]Even so, Sonnenschein Nath & A ; Rosenthal LLP feels that the SEC ‘s attempts to ‘codify ‘ are highly unneeded. They claim that the American Securitization Forum ‘s Disclosure Package includes similar information about borrowers, “ reflecting the industry position that these points are appropriate in the context of publically available loan degree informations. ”[ 19 ]With all of this in head, if the SEC can react to these remarks by guaranting that adequate personal information is protected, this new alteration will be highly effectual at increasing the transparence of ABS revelations.

After thorough analysis of this alteration, I have attempted to build the format and presentation of a “ sample ” revelation under the new regulations utilizing Microsoft Excel ( fabricated Numberss ) .

Table 4.2 Asset Data File

This revelation shows an illustration of a loan-level “ Asset Data File ” for a specific car loan underlying a security in Tranche C of plus pool 2006-A. It portrays some of the general information of the loan and borrower, including loan sum and FICO score, every bit good as asset-type specific informations, such as the auto theoretical account and value of the auto. The proposed regulation will besides necessitate patrons to unwrap any alterations to the plus informations on an on-going footing. This will assist to maintain investors cognizant of the true value and hazard of their securities at any clip during the investing procedure. As a whole, this alteration will supply investors with more touchable information in an ‘easier-to-analyze ‘ format and on a more consistent footing.

4.2 SEC Computer Model for Analyzing Securities

Under the current Regulation AB revelation demands, merely a narrative description of the waterfall has to be disclosed to investors in the Prospectus in PDF format. A drumhead chart of the waterfall for Chase Auto Owner Trust 2006-A from the prospectus is presented below. The full prospectus and textual description of the waterfall can be viewed at the JPMorgan & A ; Chase web site.

Figure 4.1 Priorities of Payments and Distributions

Beginning: JPMorgan.com

This chart shows the precedence of payments and distributions of hard currency flows for this specific trust. The existent waterfall in the prospectus is highly drawn-out and describes “ how the borrowers ‘ loan payments are distributed to investors in the ABS, how losingss or deficiency of payment on those loans is divided among the investors, and when administrative disbursals ( such as serving fees ) are paid to service suppliers. ”[ 20 ]Although the qualitative information presented in the waterfall is helpful to investors, it still leaves them with deficient informations to carry on a proper quantitative analysis, which is likely the more of import of the two. The PDF format besides limits the investor as they are unable to set the information from clip to clip to reflect updated plus public presentation.[ 21 ]

In visible radiation of these jobs, the SEC has aimed to supply investors with the ability to independently measure their ain hazard and go less dependent on 3rd parties ( e.g. recognition bureaus ) . Under the proposed regulations, issuers must register on the SEC website a computing machine plan ( hard currency flow theoretical account ) picturing the waterfall. The plan must be created utilizing “ Python ” unfastened beginning engineering and made available on EDGAR so that it is easy accessible to investors.[ 22 ]This will enable investors to consistently “ re-input information sing the pool assets and re-model projected hard currency flows and allotment of losingss. ”[ 23 ]

Over the past several months, there has been much argument environing the effectivity of such a theoretical account. Harmonizing to investing banker and adviser Daniel Indiviglio, “ the load of analysis should be placed on the investor. ” The trust on this one-size-fits-all computing machine theoretical account “ would merely ensue in the same kind of lazy investor job that led to excessively much demand for bad securities in the first topographic point. ”[ 24 ]However, the usage of unfastened beginning through Python disproves Indiviglio ‘s statement because it enables the investor to analyse the theoretical account and input their ain premises if necessary. It besides saves them the clip and complication of building their ain theoretical account that could even be inaccurate. ABS issuers have more information sing the implicit in assets and are more capable of building an efficient theoretical account.

Furthermore, the pick of programming linguistic communication has besides been a beginning of important argument. While computing machine scientific discipline professionals do believe that a computing machine package theoretical account is a measure in the right way, they have expressed some concern about Python ‘s capablenesss. In his remark missive, Computer Scientist Sameer Sundresh states that the SEC “ should travel towards utilizing a more formally-specified pure functional scheduling linguistic communication. ” He claims that Python is extremely susceptible to error and excessively luxuriant for the mean investor to understand.[ 25 ]If the SEC can successfully weigh these sentiments and pick the most efficient computing machine plan, this new demand will hold a immense impact on securitization markets. Not merely will it increase the sum of quantitative informations available to investors, but besides heighten their ability to analyse this information.

After carry oning my empirical analysis, I have attempted to make a “ Sample Computer Model ” utilizing Microsoft Excel, which helps to exemplify the underlying features of the proposed revelation ( fabricated Numberss ) . The theoretical account is based on the drumhead chart of the waterfall for Chase Auto Owner Trust 2006-A which was depicted above.

Figure 4.2 Computer Model

This file shows a sample revelation of the SEC Computer Model for a given period. Upon the issue of its asset-backed securities, the issuer will be able to make this theoretical account utilizing the statistics and textual description of the waterfall from the prospectus. It will input the information into Worksheet 3 “ Prospectus Data ” and so input different involvement rate, prepayment, default, and loss-given default premises into Worksheet 2 “ Input Assumptions. ” The issuer will so be able to bring forth a hard currency flow waterfall that links the specific payouts and loss per centums to the old two worksheets. For illustration, in this SEC computing machine theoretical account, with a 10 % default rate and 5 % prepayment rate, Class R certifications lose 50 % of its principal and Tranche A and B chief get paid down by $ 15,500 and $ 8,500, severally. Each tranche besides receives certain involvement payments based on the involvement rates from the premises check.

As shown by this sample revelation, the SEC computing machine theoretical account will supply investors with more touchable information, every bit good as the ability to continually pull off the information to decently measure the hazard and values of their investing. Investors will be able to easy download these revelations off of EDGAR and reexamine the waterfall outright. Through the usage of the unfastened beginning engineering, they can easy set the premises if needed and re-run several hard currency flow simulations within proceedingss. This new revelation demand will give investors more clip and information to efficaciously supervise the on-going public presentation of the ABS, taking to more elaborate analysis and better investing determinations.

4.3 Issuer CEO Certification

Under the current Regulation AB, asset-backed securities have to have an investing class evaluation by a recognition bureau before they could be issued to investors. Alternatively, the new regulation requires that the issuer provide a CEO enfranchisement saying that:

The CEO has reviewed the prospectus and necessary paperss and to his or her cognition, the assets have features that provide a sensible footing to believe they will bring forth, taking into history internal ( but non external ) recognition sweetenings, hard currency flows sufficient to do payments on the securities as described in the prospectus.[ 26 ]

Due to the nature of this proviso, there has non been much argument sing its impact on securitized minutess. After extended research, it is apparent that this demand will positively impact the ABS market. First, it suitably shifts answerability from recognition bureaus back to the patrons of the securitization. It places duty on the CEO of the issuer to supervise the dealing and guarantee that the implicit in assets are of good adequate quality to bring forth the promised hard currency flows.[ 27 ]Second, it helps to switch the hazard of loss from investor back to the issuer. Harmonizing to Securities Act Section 17, “ an officer supplying a false enfranchisement potentially could be capable to Commission action. ”[ 28 ]So if investors experienced important losingss due to plus underperformance, they would now hold legal claims against the patron. Although some feel that this addition in answerability could restrict the supply of asset-backed securities, it is an of import measure to take to increase investor religion in the markets through safer investing merchandises.

4.4 Risk Retention

Under the current regulations, there is no demand for the patron of the securitization to retain any involvement in the securities. This resulted in the packaging and issue of highly hazardous securities, frequently coming at the disbursal of the investor. To assist relieve this job, the SEC has proposed that the patron of a securitized dealing retain at least a 5 % perpendicular piece of each tranche and keep this involvement on an on-going footing. By necessitating hazard keeping, the thought is that “ because the patron retains exposure to the hazard of the assets, the patron is more likely to be incentivized to lend higher quality assets to the pool. ”[ 29 ]

This alteration has spurred some argument between industry professionals. While some agree that it will bring forth higher quality securities, others believe it will do unintended complications. Harmonizing to a spouse at Deloitte, the 5 % tegument in the game demand could “ do confusion sing the consolidation issues raised in Financial Accounting Standards ( FAS ) 166 and 167. ” Under these criterions, an issuer must consolidate an SPE if it has: 1 ) the power to direct the economic activities of the entity and 2 ) the ability to absorb losingss or have benefits that are potentially important. Although the 5 % piece does non run into the quantitative standards for consolidation under Fin46R, it is much more equivocal under the qualitative standards of FAS 167.[ 30 ]

Harmonizing to the Committee on Capital Markets Regulation, a 5 % tegument will besides expose patrons to excessively much hazard. It would coerce fiscal establishments to go on to keep hazardous, illiquid assets on their balance sheet, which in bend will significantly impact capital demands and the handiness of recognition.[ 31 ]Furthermore, many industry professionals have disagreed with the thought that a perpendicular piece, instead than horizontal, would break aline the involvements of patrons and investors. In a recent remark missive by Martin Hughes, the President and CEO of Redwood Trust, he states that:

A patron that is exposed to important first loss horizontal hazard is to the full exposed to the weakest assets included within a securitized pool. By contrast, a patron that is merely exposed to perpendicular hazard may merely be exposed to 5 % , for illustration, of losingss that may happen with regard to the weakest assets included in a securitized pool.[ 32 ]

The positions presented supra, although of import points to see, by no agency annul my statement that hazard keeping will be good to securitization markets. Although it will expose patrons to more hazard, it will assist to extinguish hapless loaning patterns and reconstruct sound structured minutess backed by higher quality loans. The “ perpendicular piece ” proviso is besides a critical facet of this regulation, as the fiscal crisis clearly proved that even the highest rated tranches do non ever execute as promised.

However, “ history has shown that a one-size-fits-all attack ” is non ever effectual. Therefore, it is of import for the SEC to construct in flexibleness with respects to its keeping demands, particularly higher choice assets, to guarantee proper growing and recognition handiness in the market.[ 33 ]


5.1 Summary of Research

In order to carry on my analysis, I used both primary and secondary informations. For the two revelation commissariats, I analyzed the Proposal and related remarks, while analyzing the SEC filings and revelations of JPMorgan Chase & A ; Company. Available on its web site, I specifically referred to the Prospectus and Static Pool Data of the Chase Auto Owners Trust, 2006-A. I besides leveraged these beginnings to calculate future revelations under the proposed regulations. For the enrollment commissariats, I studied the Proposal and related remarks, every bit good as published articles to assist research the effects of these regulations.

5.2 Presentation of Main Conclusions

After carry oning my analysis, I found that the four proposed alterations to ABS ordinance will be good to the securitization markets. As shown by the forecasted revelations, the new regulations will assist to increase transparence and bridge the information spread between issuer and investor. The “ Asset Data File ” will supply investors with more farinaceous information and the SEC Computer Model will enable investors to execute more quantitative analytics.

The new enrollment demands, extinguishing the markets reliance on recognition evaluation bureaus, will assist to re-allocate the hazard of loss by alining the involvements of issuer and investor. The hazard keeping demand will bring forth higher quality securities by necessitating issuers to hold some tegument in the game. The CEO enfranchisement regulation will besides assist to take down investing hazard by puting more answerability on the issuer and guaranting loan information is as advertised.

If these regulations are passed, we will see drastic betterments in the securitization markets over the following few old ages. Sound underwriting schemes will no longer take a back place to immediate net incomes. The heightened ordinance will vouch the creative activity of safer investing merchandises and more educated investing determinations. As investor religion is restored, demand will lift, increasing the handiness of recognition and strength of the fiscal markets as a whole.

5.3 Possible Restrictions to Research

The restrictions to research for this subject include unavailability of informations and inability to carry on quantitative analysis. Since the start of the fiscal crisis, the securitization market has become highly hibernating due to the high hazard of plus underperformance. As a consequence, this paper focused on revelations from 2006, since it was the most recent available. In add-on, due to the nature of this subject, it was hard to carry on a quantitative analysis of my findings ( e.g. statistical arrested development, sensitiveness analysis ) . Therefore, the empirical informations and decisions discussed in this paper were by and large qualitative.

5.4 Ideas for Future Research

Although the proposed regulations supra will assist to better the strength of the ABS market, they should non be viewed as the be-all and end-all attack. As the fiscal crisis showed, jobs within the securitization markets are huge and therefore will take several old ages to to the full mend. As the SEC prepares its following stairss, it should switch its attending to the beginning of the underlying job: the existent assets underlying the securities ( e.g. mortgages, pupil loans, recognition card receivables ) . By heightening the ordinance of mortgages and loans, the built-in hazard of asset-backed securities will fall. In add-on, the SEC must concentrate on modulating the complexness of securitized merchandises. Although the alterations set Forth above will assist to increase transparence, it is hard for investors to understand and analyse investings that are delinked and repackaged several times even when provided with ample information.