Fitch Ratings affirms the class A-1 and class A-2 notes issued by NewStar Clarendon Fund CLO LLC (NewStar Clarendon) at 'AAAsf'. The Rating Outlook remains Stable.

KEY RATING DRIVERS

The affirmation is based on the credit enhancement (CE) available to the notes and the stable performance of the underlying portfolio since the transaction's inception in January 2015.

The loan portfolio par amount plus principal cash is approximately $401.4 million (excluding PIK and capitalized interest amounts), as of the Nov. 16, 2015 trustee report, resulting in a marginal increase in CE for the class A-1 and class A-2 notes. All collateral quality tests, concentration limitations, and coverage tests are in compliance, and there are no defaulted assets in the portfolio.

The portfolio is managed to a Fitch Test Matrix, featuring various combinations of permitted Fitch weighted average rating factor (WARF), Fitch weighted average Recovery Rating (WARR), and weighted average spread (WAS) triggers. As of the effective date on May 28, 2015, the manager selected and continues to manage to a maximum WARF of 39.0 ('B/B-'), minimum WARR of 64.75% and minimum WAS of 5.15%. As of Nov. 16, 2015, the trustee reported the Fitch WARF of 35.57('B/B-'), WARR of 77.1%, and the WAS of 6.03%. The loan portfolio (excluding cash) is invested in 85.2% senior secured middle market (MM) loans and 14.8% in broadly syndicated loans.

The Stable Outlook on the class A-1 & class A-2 notes reflects the expectation that the notes have a sufficient level of credit protection to withstand potential deterioration in the credit quality of the portfolio.

RATING SENSITIVITIES

The ratings of the notes may be sensitive to the following: asset defaults, significant negative credit migration and lower than historically observed recoveries for defaulted assets, and breaches of concentration limitations or portfolio quality covenants. Rating sensitivity analysis was conducted at close and the results were disclosed in the new issue report. Initial Key Rating Drivers and Rating Sensitivity are further described in the New Issue Report published on Feb. 20, 2015.

A comparison of the transaction's Representations, Warranties, and Enforcement Mechanisms (RW&Es) to those of typical RW&Es for that asset class is also available by accessing the reports and links indicated below.

NewStar Clarendon is a collateralized loan obligation (CLO) that is managed by NewStar Financial, Inc. (NewStar). The transaction will remain in its reinvestment period until January 2019 and will mature in January 2027. Fitch's leveraged finance group provided model- and analyst-based credit opinions for all of the non-publicly rated loans in the portfolio, based on financial statements provided to Fitch by NewStar.

This review was conducted under the framework described in the report 'Global Rating Criteria for CLOs and Corporate CDOs' using Fitch's Portfolio Credit Model (PCM) to project future default and recovery levels for the underlying portfolio. Given the stable performances of each transaction, no updated cash flow modelling was completed for this review.

DUE DILIGENCE USAGE

No third party due diligence was reviewed in relation to this rating action.

Fitch has affirmed the following ratings:

--$166,662,500 class A-1 notes at 'AAAsf; Outlook Stable;

--$66,587,500 class A-2 notes at 'AAAsf; Outlook Stable.

Fitch does not rate the class B, C, D, E and subordinated A or B notes.

Additional information is available at www.fitchratings.com.

Sources of Information:

The information used to assess these ratings was sourced from periodic servicer reports, note valuation reports, NewStar and the public domain.

Applicable Criteria

Counterparty Criteria for Structured Finance and Covered Bonds (pub. 14 May 2014)
https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=744158

Criteria for Interest Rate Stresses in Structured Finance Transactions and Covered Bonds (pub. 19 Dec 2014)
https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=838868

Global Rating Criteria for CLOs and Corporate CDOs (pub. 12 Nov 2015)
https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=873664

Global Structured Finance Rating Criteria (pub. 06 Jul 2015)
https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=867952

Related Research

NewStar Clarendon Fund CLO LLC -- Appendix
https://www.fitchratings.com/creditdesk/reports/report_frame.cfm?rpt_id=854208

Additional Disclosures

Dodd-Frank Rating Information Disclosure Form
https://www.fitchratings.com/creditdesk/press_releases/content/ridf_frame.cfm?pr_id=997773

Solicitation Status
https://www.fitchratings.com/gws/en/disclosure/solicitation?pr_id=997773

Endorsement Policy
https://www.fitchratings.com/jsp/creditdesk/PolicyRegulation.faces?context=2&detail=31

ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS. IN ADDITION, RATING DEFINITIONS AND THE TERMS OF USE OF SUCH RATINGS ARE AVAILABLE ON THE AGENCY'S PUBLIC WEBSITE 'WWW.FITCHRATINGS.COM'. PUBLISHED RATINGS, CRITERIA AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH'S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE 'CODE OF CONDUCT' SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THIRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE.