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VOLUME 32 • NUMBER 1 • WINTER 2014

The Increasing Role of Banks in Equipment Finance: Establishing a Sustainable Engine for Growth

By Charles B. Wendel

Today bank-owned finance companies account for more than half of all new lease originations. What were the drivers of this evolution, and what are the implications? Will banks continue to dominate?

Municipal Leasing: Fitting a Round Peg Into a Square Hole

By Robert Neptune

Municipal leasing is a unique segment of the leasing industry. Banks in particular can benefit from cross-selling opportunities. However, to do business in this sector, lessors must accommodate the differences while upholding their quality and performance standards.

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Copyright © 2014 by the Equipment Leasing & Finance Foundation • ISSN 0740-008X

EDITORIAL BOARD

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Municipal Leasing:

Fitting a Round Peg Into a Square Hole

By Robert Neptune

The growth prospects were exciting for the municipal leas-ing business durleas-ing its infancy in the early 1980s, as the business was highly fragmented and entrepreneurial in nature. Yet, while the size of the munic-ipal leasing industry has grown significantly over the past 30 years, the product has not found its way into the playbook of a majority of leasing and lending institutions. Nor has it matured into a more main-stream segment of the overall financing and leasing industry.1

Why has municipal leasing participation been limited to a relatively small number of finan-cial institutions, and why does there continue to be limited growth? These questions are particularly puzzling when put in the context of the many ben-efits municipal leasing offers lessors. Banks in need of earn-ing assets, for instance, should find municipal leasing to be a

Municipal leasing is

a unique segment of

the leasing industry.

Banks in particular

can benefit from

cross-selling opportunities.

However, to do

business in this

sector, lessors must

accommodate the

differences while

upholding their quality

and performance

standards.

viable product line – particu-larly if coupled with cross-sell-ing opportunities for other bank services. Manufacturers and dealers evaluating vendor pro-gram partners also may give greater weight to those who can provide municipal leasing products. These and other ben-efits of the municipal leasing product, such as tax-exempt interest income, can be sub-stantial if realized efficiently.

BACKGROUND

A municipal lease, which actu-ally is an installment loan, is used by municipal entities and some not-for-profit organizations to finance the acquisition of equipment and, in some cases, facilities. The contract acquired the “lease” handle because of the annual appropriation clause found in most municipal leases. Because the obligor has the annual right to terminate the lease if it does not appropriate

funds for the next year’s pay-ments, the municipal lease is not considered debt for state bonding purposes. This annual appropriation feature also elimi-nates the costly requirements for notice, referendum, and bond documentation normally asso-ciated with issuing municipal bonds.

From an investor’s perspective, a distinctive, added benefit to the municipal leasing product is that the interest received from the government borrower is exempt from federal and, in some cases, state income taxes. Consequently, the munic-ipal lessor can charge rates that are 35% (or more) lower than equivalent commercial rates and still earn the same after-tax return as in a commer-cial lease.

It is extremely important to recognize, however, that the municipal lease is not governed

by the same rules as a commer-cial lease or loan, nor by those rules governing a municipal bond, for that matter. Each of those financing products has a fairly rigid set of rules and requirements and includes standard operating procedures for risk rating and analysis, documentation, legal review, security interests, collateral val-uation, billing and collecting, income recognition, and gen-eral transaction administration.

Instead, municipal leasing is a hybrid that borrows certain characteristics from each of these product types. In many areas, these municipal leasing rules are less rigid than for com-mercial business. For example, because of the very low risk in municipal leasing, some of the rigid corners of the commercial business can be, and in fact are, legitimately cut to facilitate the municipal business.

Editor’s note: This article is based on a Foundation study released in July 2013 titled Municipal Leasing and the Risk of Nonappropriation, by Robert Neptune and David Wiener. The report is available at www.leasefoundation.org.

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Municipal Leasing: Fitting a Round Peg Into a Square Hole Journal of Equipment Lease Financing • WINTER 2014 • Vol. 32/No. 1

2

transactions. Generally, these are what used to be called industrial revenue bonds. How-ever, the distinction is somewhat broader in nature; therefore, qualified tax counsel should be consulted.

IMPEDIMENT 2. FUNDING

Where and how funds are generated to invest in the munic-ipal leasing business is critical to maximizing the capacity to make those investments while still preserving and protecting the tax benefits. Overall fund-ing approaches are broken into two categories, bank and nonbank. Banks are generally allowed unlimited investment in bank-qualified (BQ) tax-exempt obligations.

BQ obligations are subject to a specific rules-based definition covering the amount of the transaction, timing of issuance, and borrower characteristics. Banks also generally are sub-ject to a 20% reduction of their tax deduction for the cost of doing business. While bank investment in BQ transactions is fairly straightforward, banks can create additional capacity by creating nonbank holding Given the municipal leasing

benefits just discussed, the question, “Why is there such low acceptance of this prod-uct within the industry?” again comes to mind. The differences between municipal and com-mercial leasing and finance that primarily have contributed to the slow rate of expansion in the municipal leasing sector are in the areas of:

ƒtax treatment

ƒfunding

ƒrisk/credit

ƒadministrative and process requirements

These impediments are dis-cussed in the following sections.

IMPEDIMENT 1. TAX TREATMENT

The inability to use the tax ben-efits or the lack of capacity to hold a tax-exempt portfolio are two of the reasons given most often by financial institutions for not participating in the munic-ipal leasing business. Both of these items in a municipal lease represent a substantial deviation from taxable commercial lease or loan treatment. Maximizing the tax benefits derived from tax-exempt income is critical to creating and maintaining the economic viability of the munici-pal lease as an investment. As previously mentioned, the income on municipal leases is exempt from federal and some-times state income tax. For those institutions doing business in states that allow a tax exemption for their municipal leases, it is extremely important to track the business by state: this additional benefit can add as much as two to three percentage points to the overall tax benefit in a portfolio with national scope. Of course, one of the primary benefits of not paying income tax on this revenue is the ability to deduct the costs of doing this business against revenue generated else-where in the company.

Although the interest earned on a municipal lease is exempt from tax, the true value of this exemption is only realized if the interest expense on the debt used to fund the lease is deduct-ible. Section 265(2) of the Inter-nal Revenue Code, however, provides that the interest on debt incurred to purchase or carry tax-exempt obligations is not deductible.

To avoid the disallowance of interest expense deductions the application of Sec. 265(2) requires the lessor to insure there is no direct linkage between the lessor’s debt and the acquisition of its tax-exempt obligations. In turn, the IRS is burdened with the audit responsibilities nec-essary to insure that the lessor has acted appropriately in its compliance with Sec. 265(2). Fortunately, the IRS has eased the administrative burden on all parties by allowing for some lenience in determining the amount of interest expense attributable to the tax-exempt obligations.

For instance, if the lessor’s invest-ment in tax-exempt obligations is insubstantial, borrowing for the purpose of purchasing or carrying tax-exempt obligations

ordinarily will not be inferred, meaning that the interest on the debt is deductible. The les-sor’s investment in tax-exempt obligations is considered insub-stantial if, during the taxable year, the average amount of its tax-exempt obligations does not exceed 2% of the average total assets of the business. This exception, provided in IRS Reve-nue Procedure 72-18, is known as the “de minimis rule.”

Rev. Proc. 72-18 also provides a safe harbor for companies selling their products and ser-vices directly to state and local governments. In those cases, any debt incurred by a manu-facturer to acquire non-nego-tiable tax-exempt obligations in payment for its goods will not be excluded as a nondeduct-ible expense under Sec. 265. Consequently, manufacturers willing to hold those obligations on their books to term are not penalized with a disallowance of their related interest expense.

It is also important to note that the revenue on most transactions financed for municipal govern-ment entities is exempt from alternative minimum tax. This is not true for tax-exempt financ-ings done as “private activity”

To avoid the

disallowance of interest

expense deductions

the application of Sec.

265(2) requires

the lessor to insure

there is no direct

linkage between the

lessor’s debt and the

acquisition of its

(4)

company subsidiaries to invest in nonbank qualified business. Those entities then become sub-ject to the nonbank rules and regulations described above.

Another funding issue is created by the fact that, for purposes of the de minimis rule, the IRS does not allow corporations to make the 2% calculation on a consol-idated basis. Consequently, an institution with multiple subsidiar-ies under one parent must show a pro rata amount of its tax- exempt investments under each of its subsidiaries (not exceeding 2% of assets in each case) in order to maximize investment capacity.

In the past, this was accom-plished by transferring trans-action ownership to each subsidiary. More recently, it has been established that a subsid-iary limited liability corporation (LLC) can be created to hold all the tax-exempt assets. The LLC is owned by all the other subsidiaries in amounts that would comply with the 2% rule. This method saves substantial administrative work associated with subsequent transaction assignment and changes in the asset bases of the underlying subsidiaries.

In all cases of nonbank invest-ment, an important fact to remember is that specific bor-rowing cannot be linked to spe-cific investments. Simply put, if a company borrows $10 million today and makes a subsequent $10 million investment in tax- exempts on the same day, or very shortly thereafter, it is highly likely that borrowing expenses will be disallowed as a deduc-tion, as even the de minimis rule does not allow protection when such direct linkage is evident.

A more recent development in funding municipal business is the use of all-equity subsidiaries, as investments made solely from equity eliminate the problem of the potential disallowance of interest expense. Establishing an all-equity subsidiary is a complex undertaking, and it is dependent on the specific cor-porate and tax structure of each individual institution, however. In the past few years, both banks and nonbank financial institu-tions have created all-equity subsidiaries to fuel their munici-pal leasing business.

An additional tool that can be used by both bank and non-bank institutions to fund their municipal leases is

securitiza-tion. Tax-exempt securitizations are different from those for taxable products, though, and are sold to a completely differ-ent audience, primarily large tax-exempt funds. When the financial markets were crash-ing in late 2008, and taxable securitizations were difficult to consummate, one company securitized several hundred mil-lion dollars in tax-exempt leases with extremely attractive rates and terms.

Although prior to 2009, tax- exempt lease securitizations were done with credit enhance-ment and liquidity guarantees, more flexible securitization vehicles have been developed. It now is possible to structure tax-exempt sales with senior/ subordinated structures, without liquidity, and with floating or fixed-rate structures.

IMPEDIMENT 3. RISK/CREDIT

A key factor potentially imped-ing additional market entry and investment growth in municipal leasing is the concern of credit risk, most pointedly, the prospect of nonappropriation of funds by the governmental entity. The Alta Group recently completed a

research study for the Equipment Leasing & Finance Foundation titled Municipal Leasing and The Risk of Nonappropriation.

This study was commissioned in response to requests from municipal leasing business and sales managers for background information and market data to help alleviate the concerns of risk managers and senior man-agement regarding what is seen as one of the most critical risks of municipal leasing: nonappro-priation.

Absent a full understanding of municipal historical data and performance, the issue of potential nonappropriation can heighten this concern substan-tially. In order to address this critical element of the municipal leasing credit process lessors should be prepared to:

ƒReview and assess the obli-gor’s past, present, and pro-jected financial strength.

ƒReview and assess both local and regional economic sta-bility.

ƒEvaluate the essentiality of the asset(s) being financed.

Although this approach sounds pretty basic, it is essential that

the credit department have the right resources to carry it out. For example, is there someone in credit underwriting who understands municipal fund accounting, and does he know how to access and analyze the impact of economic data?

All three areas of credit analysis mentioned above speak directly to the goal of eliminating, or at least minimizing, the occur-rences of nonappropriation and default. Given the concern over this happening, what do historical nonappropriation rates look like? The answer is that, for quite a few years now, nonap-propriation and default percent-ages for municipal leases have

When the financial

markets were crashing

in late 2008, and

taxable securitizations

were difficult to

consummate, one

company securitized

several hundred

million dollars in

tax-exempt leases with

extremely attractive

rates and terms.

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Municipal Leasing: Fitting a Round Peg Into a Square Hole Journal of Equipment Lease Financing • WINTER 2014 • Vol. 32/No. 1

4

been trending toward zero per-cent, as is illustrated in Table 1.

Table 1 shows nonappropriation percentages for the years 2008 through 2012, as compiled by the Association for Gov-ernmental Leasing & Finance (AGLF). The most recent surveys show that nonappropriation ranged between 0.0455% and 0.0003%. Furthermore, nonappropriations during the 2008–2009 recession showed only slight increases, which have since receded. The AGLF reported for 2012 that non-appropriation, as a percent of portfolios, was 0.0019%.

These studies also failed to iden-tify any trends for either of these

events, other than for those asso-ciated with small ticket/office product related equipment, with no apparent trends related to geography, type of lessee, length of term, or other types of collateral. A more comprehen-sive review of the nonappropri-ation numbers is available in the previously referenced Foun-dation study. The importance of ongoing access to municipal leasing as a financing option explains why these numbers have been so low and why they will likely remain low.

While nonappropriations and defaults are extremely low, a key factor in avoiding them is to finance essential assets. A critical step in municipal lease credit adjudication, therefore, is to understand what makes an asset essential to that partic-ular obligor. For example, fire engines are universally cited as

an example of essential equip-ment. A lessor that finances 15 fire engines for a town that only needs 10 engines, however, may find itself with some nones-sential equipment as collateral.

Municipal equipment is not essential just because the obligor says so, or because it retains its value, so it is import-ant to do some homework in each case. When leasing golf carts for the municipal golf course, for instance, resale value may be an important issue. On the other hand, when financing software that is used to calculate, assess, and collect local property taxes, residual value may be far less important, because the cost to switch and implement a new program in midstream would be prohibitive. The lessor must consider how much pain it would cause the obligor if its asset is taken away.

In commercial finance it is cus-tomary to file a UCC financing statement to perfect a security interest in the asset. In the munic-ipal leasing business, however, one must accept the fact that in most jurisdictions a security interest cannot be perfected in government-owned collateral. Comfort must be taken with the security interest granted in the document. In some cases, a promise to return the equipment in the event of nonappropriation or default is the only protection available.

In the past 30 years, there does not appear to be a case of any lessor losing its collateral due to the lack of a perfected interest. Nonetheless, a filing for notifica-tion purposes always should be made. Even though subsequent filings by other institutions would also lack perfected status, it will help to avoid the potential time

and expense associated with having another lender try to tie up the collateral in a subsequent notification filing. IMPEDIMENT 4. ADMINISTRATIVE AND PROCESS REQUIREMENTS Documentation

One area in municipal leasing that has matured and become standardized since inception is documentation. One no longer needs a 10- or 20-page docu-ment, as today’s basic municipal document can be contained in a three- or four-page document (plus attachments for certain requirements that may or may not be necessary in every transaction). Almost everything, including local counsel’s opinion as to validity, can be embed-ded in the primary document,

Table 1. Nonappropriation, 2008–2012

In the past 30

years, there does

not appear to be a

case of any lessor

losing its collateral

due to the lack of a

perfected interest.

Nonetheless, a

filing for notification

purposes always

should be made.

2008 2009 2010 2011 2012 Total portfolio ($) $8,049,581,443 $12,284,299,973 $12,252,004,875 $13,806,019,978 $13,190,560,669 # of nonappropriations 5 10 14 3 4 Amount ($) $930,000 $5,592,385 $385,632 $36,619 $246,000 Percent of portfolio 0.0116% 0.0455% 0.0031% 0.0003% 0.0019% Source: Association for Governmental Leasing & Finance.
(6)

although it may be more practi-cal to have the lease amortiza-tion as an attachment.

Every municipal lease document either must have an amortization schedule showing the interest allocation or must state the amount financed and interest rate so that the total amount of tax-exempt interest can be calcu-lated and reported. Some other critical attachments include an IRS Form 8038 and a separate acceptance certificate. Due to differences in certain state laws and requirements, separate doc-uments or document inserts may be created for those special situ-ations. This can save documen-tation time and legal costs when such changes are needed.

It also is possible to create docu-ments that approach a level sim-ilar to a snap-out form for small ticket leases. Based on very spe-cific risk-based decisions, these documents may exclude certain items that might otherwise seem absolutely essential, such as a local legal opinion. Keep in mind that it is not the opinion that makes the transaction legal, just as it is not an opinion that makes it tax exempt. Legality and tax-exemption are created by meeting certain requirements

of the law, so, as long as those requirements are met, legal opinions do not make them any more or less enforceable. Refusal of municipal counsel to issue an opinion, however, may raise a red flag.

Regardless of which market segment is targeted, best prac-tice is to have all documents constructed and reviewed by qualified Red Book bond coun-sel with expertise in municipal leasing. Given the appropriate background and instruction, counsel then can construct the best document for that purpose. Counsel also can provide advice as to where additional documentation risk may occur or be incurred. Once the proper documents are created, they can be used repeatedly, thereby simplifying counsel’s review prior to funding.

Constructing a municipal lease document by simply inserting an appropriation clause or other modification in a commercial lease will create significant problems, given that most commercial documents include language that contravenes some government protocol. The important thing to remem-ber, therefore, is to start with a

municipal document and modify it accordingly. Also note that standard municipal lease doc-uments generally will not work if financing real estate or if the borrowing entity is a not-for-profit corporation, so the best route is to have these transac-tions documented by qualified Red Book bond counsel.

After appropriate documents are created and related policies and procedures put in place, municipal lessors still may be required to use the municipal-ity’s documents. Unfortunately, those documents very well may contain incorrect or insufficient language necessary to meet desired standards. This further highlights the need to use qual-ified counsel to protect internal interests and negotiate accordingly.

Legal Concerns

In the absence of staff attorneys with extensive experience as bond counsel and, specifically, municipal leasing experience, it is advisable to hire outside counsel. Using inexperienced counsel in this market can result in making the lessor uncompet-itive, or including terms and conditions in the document that ultimately may be

unenforce-able. In addition to the initial construction of documents, qual-ified external counsel should be used for the entire transaction process, including document and transaction review and negotiation with local counsel when necessary.

It is possible for the business unit and in-house counsel to create an operating agreement with external counsel that will allow (and prepare) them to function in much the same way in-house counsel would function at the transaction level. In-house counsel then can monitor and oversee the relationship going forward. This approach will help make the business more competitive and create a higher level of confidence in the process.

Lease Administration

Billing and collection policies and existing accounting systems are not always compatible or compliant with municipal lease requirements. Shortly after set-ting up a new municipal leas-ing business, for example, a national lessor encountered past dues in excess of 5%. Upon review of the situation, the lessor determined that the work rules in the billing system were the prob-lem, not recalcitrant lessees.

Standard billings for this lessor’s commercial lease customers were mailed 20 days prior to the due date. Municipal cus-tomers, though, often have a tedious and archaic process for paying bills, including steps such as obtaining approval at the monthly board or council meeting. As a result, there is very little a municipal govern-ment can do to push an invoice through its accounts payable system in less than 30 days prior to the due date.

Once this lessor started mailing its invoices 45 days prior to the due date, the portfolio wound up being paid ahead by several days. The lesson here? Lessors should make sure the billing parameters are conducive to municipal payment

character-Regardless of which

market segment

is targeted, best

practice is to have all

documents constructed

and reviewed by

qualified Red Book

bond counsel with

expertise in municipal

leasing.

(7)

Municipal Leasing: Fitting a Round Peg Into a Square Hole Journal of Equipment Lease Financing • WINTER 2014 • Vol. 32/No. 1

7

istics and habits before blindly dropping municipal leases into a standard collection system.

Existing accounting systems also should be evaluated to make sure they can recognize the interest income correctly, as the income on a municipal lease must be accrued in accordance with strict legal requirements. Municipal leases have a hard, fixed amortization and, by law, no more interest than is

speci-fied in the initial amortization schedule can be paid.

Consequently, if a system accrues additional income based on a payment being made on any date other than the contractual due date, the customer would not be obli-gated to pay the difference. Income accrual methods also may create discrepancies between the actual amortiza-tion and the system, adversely affecting the accuracy of inter-nal accounting for tax-exempt income.

This issue becomes extremely important if the lessor sells municipal leases and retains ser-vicing and reporting obligations. Due to the tax-exempt nature of the interest, if incorrect interest income is reported to investors or buyers, it may create sub-stantial unwanted legal liability. While most systems can be adjusted or modified to appro-priately account for municipal contracts, the differences must be identified.

In most instances it is legal for a municipal obligor to pay late payment fees, notwith-standing issues associated with set amortization and interest

accrual. Late fees certainly should be billed in accordance with the terms of the contract, but be forewarned that some obligors will claim they cannot pay late fees. In some cases, late charges actually will be forbidden by statute. In many instances, however, the obligor simply will be stating policy that has no basis in law. Other municipal obligors will ignore late charges and just not pay them.

Regardless of the circumstance, the lessor should take caution in applying aggressive collection of late fees. While it is true there are many reasons why a munici-pality probably will not exercise its nonappropriation right, it may not be wise to give it a reason to consider this action more seriously, as a nonappropriation can be fueled by emotion. In general, proper billing usually results in very low delinquency.

Finally, consider examining the transaction funding process. Unlike commercial businesses, municipalities expect to get their money on the morning of the day it is promised. If the internal payment process is delayed due to a requirement that might not be appropriate for the municipal

business, the municipal business may demand an interest refund for the number of days delayed. These issues represent just a few of many process items that might impede a lessor’s ability to compete in the municipal leasing business. Attention to them will establish a mindset for identifying and dealing with roadblocks along the way, as a slight retailoring of an existing internal process can avoid many of these potential problems.

CONCLUSION

So, how does that round peg of municipal leasing fit into the square hole of commercial leasing? The answer is that it does not. A new space must be created, one that fits the differ-ent characteristics of a differdiffer-ent business. Although many com-mercial processes and system capabilities can be used, the concept that municipal leasing will fit perfectly into the commer-cial side of the business is not valid, so lessors should be open to identifying and accommodat-ing differences while remainaccommodat-ing true to their quality and perfor-mance standards. It is in this respect that the assistance of an experienced third party can be invaluable.

When considering entering the municipal leasing business, the lessor should:

ƒIdentify how the addition or expansion of municipal leas-ing will help the business.

ƒGain a full understanding of current and future tax status.

ƒIdentify, evaluate, and prior-itize all viable structures for acquiring, holding, and sell-ing tax-exempt business.

ƒAssess current comfort with municipal credit risk, nonap-propriation, and the compa-ny’s willingness to change, if necessary.

ƒAssess internal legal capabili-ties and identify and interview external options.

ƒ Identify procedural and policy adjustments necessary to deal with differences in documentation, collateral security, and funding pro-cesses.

ƒDetermine the relevant cur-rent system capabilities and the scope of any necessary changes.

It is by recognizing the unique attributes and requirements of the municipal leasing business that lessors can take advantage of, and profit from, this unique segment of the equipment leas-ing and finance industry.

Although many

commercial

processes and system

capabilities can be

used, the concept

that municipal leasing

will fit perfectly into

the commercial side

of the business is

not valid, so lessors

should be open

to identifying and

accommodating

differences while

remaining true

to their quality

and performance

standards.

(8)

Acknowledgment

The author thanks David Wiener and Shawn Halladay of The Alta Group for their assistance in completing this article.

Endnotes

1. The 2013 Survey of Equipment Finance Activity (SEFA) shows that only 33 of 86 respondents indicated participation in municipal lease activity. Total new business volume in state and local government leasing comprised only 4% of total new volume, 85% of which was done by 27 or fewer institutions that generated over $1 billion in total new volume in 2012.

Robert Neptune

bneptune@thealtagroup.com

Based in Kansas City, Missouri, Bob Neptune brings decades of experience in municipal, state, and federal leasing to The Alta Group. Serving in recent years as an industry consultant, he was pres-ident of De Lage Landen Public Finance from 2005 to 2008. There he helped integrate new products into eight business units and, in late 2008, structured and sold one of the indus-try’s largest municipal lease securitizations. Mr. Neptune was president of ORIX Public Finance from 2001 to 2005, until De Lage Landen took over ORIX’s governmental leasing business. Earlier in his career, he held senior executive positions at Trans-america Public Finance, Heller Public Finance, and Chrysler Capital Corp. He serves on the board of the Association for Governmental Leasing & Finance. He is a former member of the Equipment Leasing & Finance Association Public Finance Policy Committee and former chairman of the associations Municipal Leasing Industry Committee. Mr. Neptune holds a BA in busi-ness administration from the University of Oklahoma, Norman.

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