Market commentary
10
 min read

Tricolor Early Indicators

Tricolor’s collapse shows how rising delinquencies, higher funding costs, and falling collateral values can signal credit risk.
Published on
September 2, 2026

Overview

This week the U.S. Securities and Exchange Commission sued the founder of bankrupt subprime auto lender Tricolor Holdings and two of its executives, accusing them of double pledging collateral and misrepresenting the debt pools they were offering to lenders.1 From an investor perspective, Tricolor was particularly painful as instruments rated at “AAA” and “AA” are in default. For both Tricolor2 and First Brands Group,3 recoveries are likely to be minimal. Egan-Jones did not rate either firm or their securities and, as reflected in our historical results, our performance record continues to be strong (see Appendix A for our whitepaper).

I. Our Premise

Some claim that there was fraud and therefore the collapse was not predictable. A contrary view is that there is often fraud and that sophisticated investors and risk managers would be well served to examine some of those signs. Obligors mask the true conditions in an attempt to “fake it until they make it”. Regardless, it is worthwhile revisiting some early indicators.

II. Tricolor Problems

For Tricolor, the business was heading in the wrong direction as the credit quality of obligors was weakening while the value of collateral had become increasingly suspect. In the case of the obligors (i.e., the lessees and auto purchasers), which were typically weaker credits, they have been hit with immigration enforcement, inflation, and a weaker employment market. As can be seen below, the delinquency rate on all consumer loans jumped from approximately 1.5% in early 2021 to 2.8% in late 2024; surely it was significantly greater for subprime borrowers, which was Tricolor’s customer base.

Exhibit 1. Delinquency Rate on Consumer Loans, All Commercial Banks
Source: Board of Governors of the Federal Reserve System (US) via FRED, series DRCLACBS.

Meanwhile, the cost of financings leapt from 4.5% in early 2022 to a high of 8.4% in 2024.

Exhibit 2. Finance Rate on Consumer Installment Loans at Commercial Banks, New Autos 60 Month Loan
Source: Board of Governors of the Federal Reserve System (US) via FRED, series RIFLPBCIANM60NM.

Lastly, the value of Tricolor’s collateral was collapsing as shown by the below diagram:

Exhibit 3. Consumer Price Index for All Urban Consumers: Used Cars and Trucks in U.S. City Average
Source: U.S. Bureau of Labor Statistics via FRED, series CUSR0000SETA02.

So, there you have it, a triple whammy:

  1. higher delinquencies,
  2. increased borrowing costs, and
  3. declining collateral value.

While none of this is definitive, certainly these signs warrant additional due diligence.

III. Setting the Record Straight

The appropriate measure of a credit rating is how it performs over time. The attachment provides support for our superior performance.

IV. Conclusion

Our view is that credit quality shifts can often be identified through observable indicators. We were fortunate in flagging Enron and WorldCom and being named number one by Fortune Magazine for warning about the 2008 Credit Crisis.4 We aim to continue providing timely, accurate ratings.

Appendix A - White Paper

Egan-Jones Ratings: Broad Acceptance & Proven Performance

Egan-Jones Ratings was founded at the request of major institutional investors to provide timely and independent credit ratings. The information below presents one measure of Egan-Jones’ historical ratings performance.

Egan-Jones Ratings Company delivers global credit ratings for corporate debt, real estate, insurance, financial institutions, and alternative assets. Egan-Jones rates a variety of unsecured and collateralized instruments, such as those backed by receivables, land, consumer debt, litigation settlements, inventory, leases, equipment, commodities, royalties, intellectual property, and other assets. Investment vehicles such as feeder and master funds are also rated by Egan-Jones.

I. Broad and Wide Acceptance

Egan-Jones Ratings has achieved broad and wide acceptance among domestic life insurance groups and companies. 49 of the top 50 groups / companies hold private placements or other solicited instruments rated by Egan-Jones.5,6

Hence, a rating of solicited debt from Egan-Jones is likely to be widely accepted by domestic life insurance companies.

II. Proven Performance

Egan-Jones’ solicited debt ratings have outperformed expectations. Each rating has an embedded probability of default within the next 12 months. Multiplying the number of outstanding ratings by each rating’s probability of default yields the expected number of defaults.

For example, if an investor holds 10 instruments for which the implied probability of default is 10%, 1 default would be expected in the next 12 months (i.e., 10 instruments x 10% PD = 1).

Egan-Jones’ unsolicited ratings were similar to those of one of the two legacy rating agencies in 2025, within 0.07 notches (weighted average) for the 1,138 issuers rated by both Egan-Jones and that agency. The other legacy rating agency had an equal or higher rating relative to Egan-Jones, 63.5% of the time.

A study by the European Securities and Markets Authority (ESMA) determined no notching was needed for Egan-Jones’ ratings.10 A June 2022 Morgan Stanley study determined one of the legacy rating agencies had higher default rates than Egan-Jones.

Appendix B - Recent CLO Rating Actions

The ten most recent Egan-Jones CLO tranche ratings are shown below alongside the other NRSRO’s equivalent rating on the same tranche and the current collateral test cushions.

Egan-Jones Ratings Company CLO rating reports; report data as of 05/13/26. Every rated tranche is listed in the complete Egan-Jones CLO ratings table at egan-jones.io/non-nrsro-ratings/clo.
Diff is the gap in notches between the Egan-Jones rating and the other NRSRO’s equivalent rating on the same tranche. Green is Egan-Jones higher; red is Egan-Jones lower. Cushion is the current test level divided by its trigger, so a figure below 1.00 means the test is failing. “n/a” appears where the report shows no interest coverage test for that class. Egan-Jones ratings shown here are not NRSRO ratings.

Sources & Footnotes

  1. U.S. Securities and Exchange Commission, “SEC Charges Former Executives With Fraud in Connection With $1.9 Billion Collapse of Subprime Auto Lender Tricolor,” Press Release 2026-77, August 18, 2026.
  2. Scott Carpenter and Isabella Farr, “Tricolor’s $945 Million of ABS Cut to CCC and Lower by KBRA,” Bloomberg Law, September 22, 2025.
  3. Lucy Carter, “Ratings & Analysis: First Brands Group issuer ratings plunge,” The DESK, September 30, 2025.
  4. “Egan-Jones Ratings Company,” Wikipedia.

    Appendix A footnotes

  5. Data analysis validated by RiskSpan, Inc.

  6. Data Source: National Association of Insurance Commissioners 2024 Schedule D filings, by permission. The NAIC does not endorse any analysis or conclusions based upon the use of this data. Market share determined by total actual cost as reported in 2024 NAIC Schedule D filings.
  7. “Rated deals” are based on the number of outstanding ratings on January 1 of the current calendar year. In cases of multiple instruments or tranches included in one ratings letter, the instruments/tranches are treated as one “Rated deal” in the above table.
  8. The “Expected default” number is based on the issuer or obligor rating in the deal. If the issuer or obligor rating is not available, the highest rated instrument is usually selected for the deal.
  9. Defaults are based on publicly available filings that occurred during the applicable year. The methodology for the calculation of the number of defaults is consistent with the calculation of the number of “rated deals.” The “expected” and “known actual” number of defaults are calculated by treating all rated instruments/tranches in one ratings letter as one “rated deal” and the default of multiple instruments included in one rating letter is treated as one “expected” and one “known actual” default.
  10. Source: eba.europa.eu, Final report on the amendment of the Implementing Technical Standards on the mapping of ECAIs’ credit assessments.

Additional Sources

  • Exhibit 1: Board of Governors of the Federal Reserve System (US), Delinquency Rate on Consumer Loans, All Commercial Banks (DRCLACBS), via FRED, Federal Reserve Bank of St. Louis.
  • Exhibit 2: Board of Governors of the Federal Reserve System (US), Finance Rate on Consumer Installment Loans at Commercial Banks, New Autos 60 Month Loan (RIFLPBCIANM60NM), via FRED, Federal Reserve Bank of St. Louis.
  • Exhibit 3: U.S. Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers: Used Cars and Trucks in U.S. City Average (CUSR0000SETA02), via FRED, Federal Reserve Bank of St. Louis.
  • Appendix B CLO table: Egan-Jones Ratings Company CLO rating reports and trustee data, published at egan-jones.io/non-nrsro-ratings/clo.
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