The MAS requirement remains for an issuer to provide legal confirmation of the ringfencing of assets, whether via an SPV or through declaration of trust.
This would also be the case where there is a time lag for when mortgage assets can be substituted into the cover pool.
This is especially true for the issuance of hard-bullet covered bonds, where there is no grace period to liquidate assets as part of the terms of the bonds. In some cases, a pre-maturity test is used to trigger the collateralisation of bonds maturing in the coming 12 months.
The proposed rules will give programmes that issue hard-bullet bonds the ability to hold cash assets in excess of the 15% limit to fund such maturing covered bonds