Section 8 – Other Events.
Item 8.01. Other Events.
Historically, Capital One Bank (USA), National Association (“Capital One”) and itspredecessor-in-interest, World’s Foremost Bank, charged off accounts comprising the portfolio of Cabela’s CLUBco-branded credit cards, including the accounts comprising the Cabela’s Master Credit Card Trust portfolio, no later than when the account was approximately 130 contractual days past due. As part of the ongoing efforts of Capital One to integrate the portfolio of Cabela’s credit card accounts onto its legacy origination and servicing systems, Capital One has changed thecharge-off policy for these accounts to conform to its corporate policy, which is to charge off these accounts no later than when the account is approximately 180 contractual days past due.
The effect of this change in thecharge-off policy for the Cabela’s credit card accounts will be to delay the charge off of delinquent receivables in these accounts by up to approximately 50 additional days. Thisone-time deceleration will substantially reduce these charge offs during the months of October and November 2018. Capital One does not expect this change to have a long-term effect on the level of reported charge offs in the Cabela’s credit card accounts or an effect upon the payment of principal and interest on the notes issued by Cabela’s Credit Card Master Note Trust. This statement is a forward-looking statement, subject to certain risks and uncertainties. Other conditions or events could have a material adverse effect upon the level of reported charge offs in the Cabela’s credit card accounts and the payment of principal and interest on the notes issued by Cabela’s Credit Card Master Note Trust. Many of these conditions or events are beyond our control, such as a material increase incharge-off rates for the Cabela’s credit card accounts or in the rate of interest payable to holders of notes issued by Cabela’s Credit Card Master Note Trust.
In connection with this change in thecharge-off policy for the Cabela’s credit card accounts, for purposes of the accounts comprising the Cabela’s Master Credit Card Trust portfolio, we have revised the measure of the threshold amount of delinquencies that must be reached under the delinquency trigger relating to an asset representations review in order to maintain a consistent measurement relative to the delinquency trigger rate both before and after this change incharge-off policy. This delinquency threshold was originally established under the prior130-daycharge-off policy and the measure was based on the average for any three consecutive calendar months of the delinquency rates for receivables in the Cabela’s Master Credit Card Trust portfolio that were 60 or more days delinquent, measured as of the end of the related monthly periods. Under the new180-daycharge-off policy, the measure is based on the average for any three consecutive calendar months of the delinquency rates for receivables in the Cabela’s Master Credit Card Trust portfolio that are 60 or more days delinquent but less than 130 days delinquent, measured as of the end of the related monthly periods. This revised measure of delinquencies used for purposes of the delinquency trigger maintains consistency relative to the delinquency trigger rate both before and after this change incharge-off policy by continuing to measure delinquencies to and including the point at which the related Cabela’s credit card accounts would have been charged off under the prior policy.
On October 9, 2018, WFB Funding, LLC, as Transferor, Capital One Bank (USA), National Association, as Servicer, and U.S. Bank National Association, as Trustee, executed the First Amendment to Third Amended and Restated Pooling and Servicing Agreement, which implemented this revised measure of delinquencies used for purposes of the delinquency trigger, and is filed as Exhibit 4.1 to this Current Report on Form8-K.
Section 9 – Financial Statements and Exhibits.
Item 9.01(d). Exhibits.
Exhibit Index
Each of the following are filed as an Exhibit to this Report.
| | |
| |
Exhibit 4.1 | | First Amendment to Third Amended and Restated Pooling and Servicing Agreement, dated as of October 9, 2018, by and among WFB Funding, LLC, as Transferor, Capital One Bank (USA), National Association, as Servicer, and U.S. Bank National Association, as Trustee. |