Fitch Rates Puerto Rico's $441MM Subordinate Lien Sales Tax Revs 'A+'; Outlook Stable

NEW YORK--()--Fitch Ratings assigns an 'A+' rating to the Puerto Rico Sales Tax Financing Corporation (COFINA) bonds as follows:

--$398.509 million sales tax revenue bonds, first subordinate series 2011A;

--$42.34 million sales tax revenue bonds, first subordinate series 2011B (local bonds).

The bonds are expected to sell via negotiation on or around Nov. 14, 2011.

Fitch also affirms the 'A+' rating on COFINA's $8.5 billion of outstanding first subordinate sales tax revenue bonds and the 'AA-' on $5.2 billion of outstanding senior lien bonds.

The Rating Outlook for both the senior and subordinate lien bonds is Stable.

KEY RATING DRIVERS

--The ratings on the senior and subordinate lien bonds reflect a structure and revenue pledge that insulates the bonds from the strained general fund operations of the commonwealth.

--Bonds have a first claim on all commonwealth sales tax revenues, providing strong current coverage.

--The legal opinions are strong, finding that neither the commonwealth general fund nor commonwealth GO bondholders have a claim on pledged sales tax revenues.

--Enhancements to the bond resolution, in particular a strengthening of non-impairment language, provide some additional protection to bondholders.

--The sales tax base is broad and the retail environment in Puerto Rico has shown strength even in challenging economic times. The collection rate is weak but improving.

--The final maturity of both the senior and subordinate lien bonds is very long, and the program's rising debt service profile requires some growth in revenues to achieve coverage of later maturities. Additional risks include the commonwealth's strained fiscal and economic environment.

SECURITY

The bonds represent a limited obligation of COFINA, payable from pledged revenues (sales and use tax) subordinate lien to outstanding senior lien bonds. COFINA is an independent governmental instrumentality of the commonwealth and affiliate of the Government Development Bank of Puerto Rico (GDB).

CREDIT PROFILE

The bonds are secured by a portion of the commonwealth's island-wide sales and use tax, which became effective on Nov. 15, 2006. This broad-based tax was instituted as part of Puerto Rico's 2006 tax and fiscal reform and its use was restructured in 2009 as part of a comprehensive fiscal and economic package designed to stimulate Puerto Rico's economy and address recurring budget deficits. The tax is currently levied at the rate of 5.5%, with a 1.5% additional municipal option. As originally structured, the commonwealth's general fund received 4.5% of the 5.5% sales tax with the remaining 1% dedicated to debt service on the senior lien bonds, which were used to retire extra-constitutional (i.e. appropriation) debt of the commonwealth. As noted in the original analysis of the structure, a key credit feature supporting the 'AA-' rating on the senior lien bonds is that the pledge for the senior lien sales tax revenue bonds is the greater of collections from the 1% or a base (minimum) amount payable from all commonwealth sales tax revenues each year. Since debt service in any year is capped at the applicable base amount, debt service on senior lien bonds will be covered by pledged revenues as long as collections from the entire commonwealth sales tax, rather than just the 1%, are sufficient to fund the base amount.

Legislation was passed in early 2009 amending the governing resolution and authorizing COFINA to issue subordinate lien bonds secured by an additional 1.75% of the 5.5% sales tax. The base amount, which was originally $185 million in fiscal 2008, rising 4% per year thereafter, has been increased to $550 million, also rising 4% per year thereafter up to a maximum of $1.85 billion. The 'A+' rating on the subordinate lien bonds incorporates coverage by the full 5.5% due to the strong flow of funds. At the start of each fiscal year, revenues from the entire commonwealth sales tax flow directly from Banco Popular de Puerto Rico, the collection agent, to the trustee until revenues deposited with the trustee in that year equal the base amount. Only thereafter does the general fund receive its share of collections.

The sales tax base is broad and diversified, with more than half derived from retail trade. There is minimal reliance on tourism and automobiles and motor fuel are excluded. Items subject to sales tax include tangible personal property, taxable services, admission fees and bundled transactions. Sales tax collections have been increasing over the past year as the economy slowly begins to emerge from recession and enforcement efforts are increased. Fiscal 2011 revenues increased 2.7% year-over-year and were just 0.6% below estimate. Sales tax collections through October 2011, the first four months of fiscal year 2012, are up 3.4% year-over-year.

Coverage of annual debt service from current revenues is ample; however, debt service escalates fairly rapidly. Sales tax revenues would have to grow .26% annually to assure 1.0 times (x) coverage of senior lien debt service throughout the life of the bonds and approximately 1.6% annually to assure 1.0x coverage of senior and subordinate lien debt service throughout the life of the bonds by the entire 5.5% tax. Even with escalating debt service and the long final maturity of the bonds, achieving this relatively low level of growth in tax revenues appears reasonable.

The 2009 legislation also strengthened non-impairment language, making it more difficult for the commonwealth to eliminate or divert the sales tax in the future. The revised resolution includes language specifying that only the non-pledged portion of the sales tax may be lowered or abolished and only if it is replaced with a 'like or comparable security'. To do so, the trustee must be provided written ratings confirmation and written opinions from the Secretary of Justice, bond counsel, and other experts concluding that the Puerto Rico Supreme Court would agree that the substituted assets/revenues have been validly imposed by law, validly transferred to COFINA, and do not constitute available resources of the commonwealth subject to the clawback provisions for GO debt in the constitution.

The 2011A and B bonds fully leverage the first subordinate revenue stream, as intended when the program was initiated in mid-2009. As with the previous issues, bond proceeds provide deficit financing, in this case for fiscal year 2012, as part of the commonwealth's ongoing fiscal restructuring plan in anticipation of new revenues and expenditure reductions bringing the budget into balance. Previous issues were used to repay outstanding extra-constitutional debt of the commonwealth, lessening the burden going forward on the general fund, and supporting the commonwealth's efforts to stimulate the local economy. The current offering includes capitalized interest and refunding bonds in order to increase the issuance capacity within the debt service cap.

Additional information is available at 'www.fitchratings.com'. The ratings above were solicited by, or on behalf of, the issuer, and therefore, Fitch has been compensated for the provision of the ratings.

Applicable Criteria and Relevant Research:

--'Tax-Supported Rating Criteria', dated Aug. 15, 2011;

--'U.S. State Government Tax-Supported Rating Criteria', dated Aug. 15, 2011.

Applicable Criteria and Related Research:

Tax-Supported Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=648898

U.S. State Government Tax-Supported Rating Criteria

http://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=648897

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Contacts

Fitch Ratings
Primary Analyst
Karen Krop
Senior Director
+1-212-908-0661
Fitch, Inc.
One State Street Plaza
New York, NY 10004
or
Secondary Analyst
Marcy Block
Senior Director
+1-212-908-0239
or
Committee Chair
Douglas Offerman
Senior Director
+1-212-908-0889
or
Media Relations
Sandro Scenga
+1-212-908-0278
sandro.scenga@fitchratings.com

Contacts

Fitch Ratings
Primary Analyst
Karen Krop
Senior Director
+1-212-908-0661
Fitch, Inc.
One State Street Plaza
New York, NY 10004
or
Secondary Analyst
Marcy Block
Senior Director
+1-212-908-0239
or
Committee Chair
Douglas Offerman
Senior Director
+1-212-908-0889
or
Media Relations
Sandro Scenga
+1-212-908-0278
sandro.scenga@fitchratings.com