Skip to main content

D. Disclosure

C 52/2017 STA Effective from 1/4/2021

9.A rating should be disclosed as soon as practicably possible after issuance. When disclosing a rating, the information should be clearly worded, and should indicate the nature of the rating and relevant limitations, while providing appropriate warning to users of the potential danger of unduly relying on the rating to make investment or other decisions.

10.To promote transparency and market discipline, an ECAI should demonstrate that it provides access to information that enables stakeholders to make decisions about the appropriateness of ratings for the intended use or uses. At a minimum, the ECAI is expected to make public the following information:

  1. Code of conduct;
  2. Definition of default;
  3. The time horizons reflected in ratings;
  4. Rating definitions;
  5. Rating methods;
  6. Actual default rates experienced in each rating category;
  7. Rating transition matrices;
  8. Whether particular ratings are solicited or unsolicited;
  9. The date of last review and update of ratings;
  10. The general nature of compensation arrangements with rated entities; and
  11. Any actual or potential conflicts of interest.

11.At a minimum, the following conflict-of-interest situations and their influence on the ECAI’s credit rating methodologies or credit rating actions must be disclosed:

  1. (i)The ECAI is being paid to issue a credit rating by a rated entity or by the obligor, originator, underwriter, or arranger of a rated obligation;
  2. (ii)The ECAI is being paid by subscribers with a financial interest that could be affected by a credit rating action of the ECAI;
  3. (iii)The ECAI is being paid by rated entities, obligors, originators, underwriters, arrangers, or subscribers for services other than issuing credit ratings or providing access to the ECAI’s credit ratings;
  4. (iv)The ECAI is providing a preliminary indication or similar indication of credit quality to an entity, obligor, originator, underwriter, or arranger prior to being hired to determine the final credit rating for the entity, obligor, originator, underwriter, or arranger; and
  5. (v)The ECAI has a direct or indirect ownership interest in a rated entity or obligor, or a rated entity or obligor has a direct or indirect ownership interest in the ECAI.

12.An ECAI should disclose the general nature of its compensation arrangements with rated entities, obligors, lead underwriters, or arrangers. When the ECAI receives compensation unrelated to its credit rating services from a party such as a rated entity, obligor, originator, lead underwriter, or arranger, the ECAI should disclose such compensation as a percentage of the total annual compensation received from that party in the relevant credit rating report or elsewhere, as appropriate. An ECAI should disclose in the relevant credit rating report or elsewhere, as appropriate, if it receives 10% or more of its annual revenue from a single party (e.g., a rated entity, obligor, originator, lead underwriter, arranger, or subscriber, or any of their affiliates).