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List of items which agencies would need to publish1
Compliance checklist: one of the options below each item to be selected
A. QUALITY AND INTEGRITY OF THE RATINGS PROCESS
1)Specification and description of Rating Process and Criteria
We have clearly specified and publicly available process and criteria for arriving at a rating
Our process and criteria are under preparation / available but not published
(Different statement, drafted by the agency)
Process and criteria not defined
2) Published and explicit Ratings Review / Appeal Process
We have a structured review and appeal process
We have a process of review but not of appeal
(Different statement, drafted by the agency)
We do not have a process of review or appeal
3)Policy on Rating Withdrawals
All assigned ratings are kept alive through their term
Ratings are withdrawn (suspended) only in extreme cases of information unavailability. In such cases the last date that the rating was updated and the fact that the rating is currently withdrawn is published in public domain
Ratings are withdrawn in cases of issuer non-cooperation
(Different statement, drafted by the agency)
4) Policy on Disclosure of unaccepted ratings
We do not reveal unaccepted ratings under any circumstances
We reveal unaccepted ratings only to regulatory agencies
(Different statement, drafted by the agency)
5)Policy on surveillance
Our rating surveillance is normally done ____times a year
(Different statement, drafted by the agency)
We have no fixed policy on rating surveillance
6)Policy on code of ethics of ratings agency and its staff
We have an explicit code of ethics signed and adopted by each member of the agency. The code of ethics is also available in public domain.
An explicit code of ethics exists and our employees are expected to follow it.
(Different statement, drafted by the agency)
We do not have a published code of ethics
7) Validity of ratings
Our ratings are valid for the life of instrument or till withdrawn or changed. This fact is externally communicated.
(Different statement, drafted by the agency)
We have no clear statement of validity of ratings
8) Publication on the Limitations of
- i) Rating Rigour
- formation adequacy
- Currency
We have a published document stating the limitations of our rating process
We do not have a published document stating the limitations of our rating process
9) Assurance or guarantee of ratings
We do not, either implicitly or explicitly, give any assurance or guarantee of a particular rating prior to a rating assessment. This policy, however, does not preclude us from developing prospecting assessments used in structured finance and similar transactions.
(Different statement, drafted by the agency)
10) Policy on Compliance Officer
We have policies and procedures that specify the role of a compliance officer and the officer's reporting lines and compensation. Policies have also been instituted that encourage employees to report activities illegal, unethical, or in any way contrary to the CRA's code of conduct to the Compliance Officer.
We do not have a separate compliance officer or policy for reporting activities that are contrary to the CRA's code of conduct
(Different statement, drafted by the agency)
11) Separation of analyst compensation and revenue from issuer
The compensation of individual analysts is not based on the amount of revenue that the CRA derives from the issuers that the analysts rate or with whom the analysts regularly interacts.
We have no policy on separation of analyst compensation and issuer revenue
(Different statement, drafted by the agency)
B. CRA INDEPENDENCE AND AVOIDANCE OF CONFLICT OF INTEREST
12)Published Policy on dependence on third parties:
- Auditors
- Trustees
- Consultants
- Experts
All information provided is taken at face value, we do not carry out any independent verification
Independent verification of information is carried out to the extent possible
(Different statement, drafted by the agency)
No policy on this issue
13)Disclosure of Interests
For all rating assignments any conflict of interest that may exist at the organizational level is disclosed at the time of the rating
(Different statement, drafted by the agency)
14) Separation of businesses
We have legally and operationally separated our credit rating business and analysts from any other business that may have a potential for conflict of interest.
We have separated operationally but not legally our credit rating business and analysts from any other business that may have a potential for conflict of interest.
We have no separation of businesses
(Different statement, drafted by the agency)
15)Disclosure of general nature of fee arrangements with rated entities
We disclose the general nature of fee arrangements with rated entities
We do not have any disclosure of the general nature of fees arrangements with rated entities
(Different statement, drafted by the agency)
16) Disclosure of non-rating revenues from rated entities
We disclose non-rating fees as a proportion of total fees received from each rated entity
We do not disclose non-rating fees as a proportion of total fees received from each rated entity
(Different statement, drafted by the agency)
17)Trading Policy for CRA employees
We maintain a trading policy for all our employees, which, amongst other things, prohibit employees from transacting in securities when they possess confidential information concerning the issuer.
We do not have any such trading policy.
(Different statement, drafted by the agency)
18) Policy on employees directly involved in the rating process initiating, or participating in, discussions regarding fees or payments with the rated entity.
We have an explicit policy regarding exclusion of rating analysts from business development activities.
We do not have any such policy.
(Different statement, drafted by the agency)
C. CRA RESPONSIBILITIES TO THE INVESTING PUBLIC, ISSUERS, AND REGULATORS
19) The Ownership of the agency
A clear and comprehensive account of the ownership has been circulated in the public domain, and is updated whenever there are significant changes in the ownership
(Different statement, drafted by the agency)
No such account has been circulated
20) The agency's Management and Board Structure
Details (age, qualifications, experience, other directorships) of the key Senior Management, and all Board Members, have been published, and are available in the public domain.
(Different statement, drafted by the agency)
Details of Management and Board Structure not published
21) Constitution of the Rating Committee
Names and Details (age, qualifications, experience, and other directorships) of the Rating Committee members, including backgrounds and qualifications, have been published, and are available in the public domain.
(Different statement, drafted by the agency)
Rating Committee details not published
22) Disclosure of what Ratings issued by the agency mean
Our ratings indicate the Probability of default of the rated instrument
Our ratings indicate Loss given default of the rated instrument
(Different statement, drafted by the agency)
23) Policy on time to communicate ratings
We publicly release our ratings within days of their being assigned and / or accepted. This is known up-front to the parties involved in the process
(Different statement, drafted by the agency)
No explicit policy on timely communication
24)Guidelines on Rating Rationale: timeliness
Our rationales are published within ____days of the rating being assigned / accepted
(Different statement, drafted by the agency)
We have no explicit policy on the timeliness of our rating rationales
25)Guidelines on Rating Rationale: content
Our rationales include factors taken into account in arriving at the rating, basic financial and operating information (restricted in case of unlisted companies), market position and business outlook
(Different statement, drafted by the agency)
We have no explicit guidelines on what our rationales should contain
26) Publication of Default and Transition statistics
(Normally default and transition statistics are compiled for ratings data over a 10-year history and with a large population of outstanding ratings)
Our default and transition statistics are compiled and disseminated regularly
Our default and transition statistics are compiled for internal analysis but not disseminated
(Different statement, drafted by the agency)
We do not compile default and transition statistics
27) Existence and publication of a Policy on Unsolicited Ratings: whether they will be undertaken, if so based on what information.
We have a publicly available and communicated policy on unsolicited ratings
We have a policy applied internally, but not externally communicated
(Different statement, drafted by the agency)
No explicit policy on unsolicited ratings
28) Policy on preserving confidentiality of privileged information (and exceptions for regulatory queries)
We do not reveal confidential information obtained during the rating exercise to anyone under any circumstances
We reveal confidential information obtained during the rating exercise only to regulatory agencies
(Different statement, drafted by the agency)
We do not have a policy on preserving confidentiality of information
D. DISCLOSURE OF THE CODE OF CONDUCT AND COMMUNICATION WITH MARKET PARTICIPANTS
29) Publication of the CRA code of conduct
We publicly disclose our code of conduct, and describe how the provisions of our code of conduct fully implement the provisions of the IOSCO code. We also explain deviations, if any, from the IOSCO code and how in spite of these deviations we achieve the objectives contained in the IOSCO provisions.
We have a code of conduct, but do not publish it in the public domain
We do not have a code of conduct
(Different statement, drafted by the agency)
30) Existence of a dedicated function/group within the organization charged with informing market participants and public regarding any questions, concerns, or complaints that the CRA may receive.
We have a dedicated function/group with our organization that takes care of the above function
We do not have such a group
(Different statement, drafted by the agency)
1To be published on the website, corporate brochures, and handed over with every rating contract and to every employee of the company. Over and above that, it is the choice of the agency where it wants to publish this checklist.
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