CA-3.4 CA-3.4 External Credit Assessments
The Recognition Process and Eligibility Criteria
CA-3.4.1
CBB will assess all External Credit Assessment Institutions (ECAI) according to the six criteria below. The CBB also refers to the IOSCO Code of Conduct Fundamentals for Credit Rating Agencies when determining ECAI eligibility. Any failings, in whole or in part, to satisfy these to the fullest extent will result in the respective ECAI's methodology and associated resultant rating not being accepted by the CBB:
(a) Objectivity: The methodology for assigning credit assessments must be rigorous, systematic, and subject to some form of validation based on historical experience. Moreover, assessments must be subject to ongoing review and responsive to changes in financial condition. Before being recognized by the CBB, an assessment methodology for each market segment, including rigorous back testing, must have been established for an absolute minimum of one year and with a preference of three years;(b) Independence: An ECAI must show independence and should not be subject to political or economic pressures that may influence the rating. The assessment process should be as free as possible from any constraints that could arise in situations where the composition of the board of directors, political pressure, the shareholder structure of the assessment institution or any other aspect could be seen as creating a conflict of interest;(c) International access/Transparency: The individual assessments, the key elements underlining the assessments and whether the issuer participated in the assessment process should be publicly available on a non-selective basis, unless they are private assessments. In addition, the general procedures, methodologies and assumptions for arriving at assessments used by the ECAI should be publicly available;(d) Disclosure: An ECAI should disclose the following information: its code of conduct; the general nature of its compensation arrangements with assessed entities; its assessment methodologies, including the definition of default, the time horizon, and the meaning of each rating; the actual default rates experienced in each assessment category; and the transitions of the assessments, e.g. the likelihood of AA ratings becoming A over time;(e) Resources: An ECAI must have sufficient resources to carry out high quality credit assessments. These resources should allow for substantial ongoing contact with senior and operational levels within the entities assessed in order to add value to the credit assessments. Such assessments will be based on methodologies combining qualitative and quantitative approaches; and(f) Credibility: Credibility, to a certain extent, can derive from the criteria above. In addition, the reliance on an ECAI's external credit assessments by independent parties (investors, insurers, trading partners) may be evidence of the credibility of the assessments of an ECAI. The credibility of an ECAI will also be based on the existence of internal procedures to prevent the misuse of confidential information. In order to be eligible for recognition, an ECAI does not have to assess firms in more than one country.January 2015CA-3.4.2
The CBB recognises Standard and Poor's, Moody's, Fitch IBCA and Capital Intelligence as eligible ECAIs. With respect to the possible recognition of other rating agencies as eligible ECAIs, CBB will update this paragraph subject to the rating agencies satisfying the eligibility requirements. (See Appendix CA-16 for mapping of eligible ECAIs).
Amended: April 2016
Added: January 2015CA-3.4.3
Conventional bank licensees must use the chosen ECAIs and their ratings consistently for each type of claim, for both risk weighting and risk management purposes.Conventional bank licensees will not be allowed to "cherry-pick" the assessments provided by different eligible ECAIs and to arbitrarily change the use of ECAIs.January 2015CA-3.4.4
Conventional bank licensees must disclose in their annual reports the names of the ECAIs that they use for the risk weighting of their assets by type of claims, the risk weights associated with the particular rating grades as determined by CBB through the mapping process as well as the aggregated risk-weighted assets for each risk weight based on the assessments of each eligible ECAI.January 2015Multiple Assessments
CA-3.4.5
If there are two assessments by eligible ECAIs chosen by a
conventional bank licensee which map into different risk weights, the higher risk weight must be applied.January 2015CA-3.4.6
If there are three or more assessments by eligible ECAIs chosen by a
conventional bank licensee which map into different risk weights, the assessments corresponding to the two lowest risk weights must be referred to and the higher of those two risk weights must be applied.January 2015Issuer Versus Issues Assessment
CA-3.4.7
Where a
conventional bank licensee invests in a particular issue that has an issue-specific assessment, the risk weight of the claim will be based on this assessment. Where theconventional bank licensee's claim is not an investment in a specific assessed issue, the following general principles apply:(a) In circumstances where the borrower has a specific assessment for an issued debt — but theconventional bank licensee's claim is not an investment in this particular debt — a high quality credit assessment (one which maps into a risk weight lower than that which applies to an unrated claim) on that specific debt may only be applied to theconventional bank licensee's un-assessed claim if this claim ranks pari passu or senior to the claim with an assessment in all respects. If not, the credit assessment cannot be used and the un-assessed claim will receive the risk weight for unrated claims; and(b) In circumstances where the borrower has an issuer assessment, this assessment typically applies to senior unsecured claims on that issuer. Consequently, only senior claims on that issuer will benefit from a high quality issuer assessment. Other un-assessed claims of a highly assessed issuer will be treated as unrated. If either the issuer or a single issue has a low quality assessment (mapping into a risk weight equal to or higher than that which applies to unrated claims), an un-assessed claim on the same counterparty will be assigned the same risk weight as is applicable to the low quality assessment.January 2015CA-3.4.8
Whether the
conventional bank licensee intends to rely on an issuer- or an issue-specific assessment, the assessment must take into account and reflect the entire amount ofcredit risk exposure theconventional bank licensee has with regard to all payments owed to it.13
13 For example, if a bank is owed both principal and interest, the assessment must fully take into account and reflect the credit risk associated with repayment of both principal and interest.
January 2015CA-3.4.9
In order to avoid any double counting of credit enhancement factors, no recognition of
credit risk mitigation techniques will be taken into account if the credit enhancement is already reflected in the issue specific rating (see Paragraph CA-4.1.5).January 2015Domestic Currency and Foreign Currency Assessments
CA-3.4.10
Where unrated exposures are risk weighted based on the rating of an equivalent exposure to that borrower, the general rule is that foreign currency ratings must be used for exposures in foreign currency. Domestic currency ratings, if separate, must only be used to risk weight claims denominated in the domestic currency.
January 2015CA-3.4.11
However, when an exposure arises through a
conventional bank licensee's participation in a loan that has been extended, or has been guaranteed against convertibility and transfer risk, by certain MDBs, its convertibility and transfer risk can be considered by CBB, on a case by case basis, to be effectively mitigated. To qualify, MDBs must have preferred creditor status recognised in the market and be included in MDB's qualifying for 0% risk rate under CA-3.2.8. In such cases, for risk weighting purposes, the borrower's domestic currency rating may be used instead of its foreign currency rating. In the case of a guarantee against convertibility and transfer risk, the local currency rating can be used only for the portion that has been guaranteed. The portion of the loan not benefiting from such a guarantee will be risk-weighted based on the foreign currency rating.January 2015Short-Term/Long-Term Assessments
CA-3.4.12
For risk-weighting purposes, short-term assessments are deemed to be issue-specific. They can only be used to derive risk weights for claims arising from the rated facility. They cannot be generalised to other short-term claims, except under the conditions of paragraph CA-3.4.14. In no event can a short-term rating be used to support a risk weight for an unrated long-term claim. Short-term assessments may only be used for short-term claims against banks and corporates. The table below provides a framework for
conventional bank licensees' exposures to specific short-term facilities, such as a particular issuance of commercial paper:Credit assessment A-1/P-114 A-2/P-2 A-3/P-3 Others15 Risk weight 20% 50% 100% 150%
14 The notations follow the methodology used by Standard & Poor's and by Moody's Investors Service. The A-1 rating of Standard & Poor's includes both A-1+ and A-1-.
15 This category includes all non-prime and B or C ratings.
January 2015CA-3.4.13
If a short-term rated facility attracts a 50% risk-weight, unrated short-term claims cannot attract a risk weight lower than 100%. If an issuer has a short-term facility with an assessment that warrants a risk weight of 150%, all unrated claims, whether long-term or short-term, must also receive a 150% risk weight, unless the
conventional bank licensee uses recognisedcredit risk mitigation techniques for such claims.January 2015CA-3.4.14
For short-term claims on
conventional bank licensees , the interaction with specific short-term assessments is expected to be the following:(a) The general preferential treatment for short-term claims, as defined under paragraphs CA-3.2.11 and CA-3.2.12, applies to all claims onconventional bank licensees of up to three months original maturity when there is no specific short-term claim assessment;(b) When there is a short-term assessment and such an assessment maps into a risk weight that is more favourable (i.e. lower) or identical to that derived from the general preferential treatment, the short-term assessment should be used for the specific claim only. Other short-term claims would benefit from the general preferential treatment; and(c) When a specific short-term assessment for a short term claim on aconventional bank licensee maps into a less favourable (higher) risk weight, the general short-term preferential treatment for inter-bank claims cannot be used. All unrated short-term claims should receive the same risk weighting as that implied by the specific short-term assessment.January 2015CA-3.4.15
When a short-term assessment is to be used, the institution making the assessment needs to meet all of the eligibility criteria for recognising ECAIs as presented in Paragraph CA-3.4.1 in terms of its short-term assessment.
January 2015Level of Application of the Assessment
CA-3.4.16
External assessments for one entity within a corporate group must not be used to risk weight other entities within the same group.
January 2015Unsolicited Ratings
CA-3.4.17
Unsolicited ratings should be treated as unrated exposures.
January 2015