Moody’s and Fitch issued provisional ratings yesterday on “VCL Multi-Compartment S.A., Compartment VCL 28”, a Lloyds-led €719.9m public auto lease ABS for Volkswagen, expected to have €705.7m Class A Asset Backed Floating Rate Notes due January 2025 rated Aaa, with €14.2m Class B and a €24.8m subordinated loan. The STS verification is by the German True Sale International. It is a static pool of 76,298 leases to obligors in Germany, average life 7.72 months and an discounted balance outstanding of €750,004,211 (the difference may be balloon/residual value payments under the contracts; these are not securitized). There are several structural protections for the AAA noteholders. Moody’s comments on and rationalizes some German insolvency law and set-off issues.