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Lesson 24 of 25 · 7 min

Holding entities, and why the choice changes the lender's analysis too

A wrapper that answers one question about treatment raises a second one about how fast a claim can be enforced.

Putting a portfolio inside an entity answers a question about treatment and immediately raises a different one about credit, and the second question is usually the one that changes a number.

On the treatment side the range is wide. Some entities are looked through, so amounts arising inside them are treated as arising directly to the owners. Others are treated as separate holders with their own periods, their own characterisations, and their own obligations. The same portfolio can therefore produce different figures depending only on the wrapper, and the wrapper usually adds administrative requirements that have nothing to do with the portfolio.

On the credit side a lender is asking something narrower: how fast can a claim be enforced. Enforcing against assets held by an entity means reading that entity's governing documents, confirming who has authority to pledge, and, if things go wrong, dealing with a counterparty that has its own creditors and its own procedures. Slower enforcement is priced the way any other delay is priced, through the advance rate. Track 8 develops that pricing from the lender's side.

The numbers move accordingly. A $5,600,000 portfolio at a 65 percent advance rate held directly carries $3,640,000 of lending value. The same portfolio inside an entity, with no guarantee from the owner, might carry 48 percent, which is $2,688,000 — $952,000 less collateral value from an identical holding. Add a guarantee and the rate might return to 61 percent, or $3,416,000, because the guarantee restores a direct route to a person.

Every rate above is illustrative. The structural point is that a wrapper is evaluated twice, by two parties asking unrelated questions, and a structure chosen for one answer can move the other by seventeen points of advance rate. Which structure does what for a particular holder is a question for their own adviser, and separately for their lender.

Key terms

Look-through
Treating amounts arising inside an entity as arising directly to its owners, so the entity is transparent for that purpose.
Separate holder
An entity treated as a taxpayer in its own right, with its own periods and characterisations rather than its owners'.
Enforcement speed
How quickly a lender can convert a claim into cash. It is a credit variable, and it is expressed in the advance rate rather than in the interest rate.

Worked example

One portfolio, three collateral values

A $5,600,000 portfolio, held directly and then inside an entity. All advance rates below are illustrative.

Held directly at a 65 percent advance rate
$3,640,000

$5,600,000 × 0.65.

Inside an entity with no guarantee, at 48 percent
$2,688,000

$5,600,000 × 0.48.

Reduction from the wrapper alone
$952,000

$3,640,000 − $2,688,000.

Inside an entity with a guarantee, at 61 percent
$3,416,000

$5,600,000 × 0.61.

Advance-rate spread across the three
17 points

65% − 48%.

Identical securities, three collateral values. The spread is an answer to a question about enforcement, asked before any question about treatment.

Check yourself

A $5,600,000 portfolio carries a 65 percent advance rate held directly and 48 percent inside an entity with no guarantee. How much collateral value does the wrapper cost, and what is the lender actually pricing?

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Educational only. Nothing in this lesson is investment, legal or tax advice, or a recommendation to enter into any transaction. Figures are illustrative and computed from the inputs stated in the lesson.

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