CRISIL s Bank Loan Ratings process, scale and default recognition

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1 CRISIL s Bank Loan Ratings process, scale and default recognition Executive Summary A CRISIL bank loan rating (BLR) reflects CRISIL s opinion on the likelihood of the financial obligations (arising out of a rated facility) being serviced on time and in full, as specified in the terms of the facility. CRISIL s process for assigning ratings to bank loans is similar to the process followed for ratings bonds and debentures. The ratings assigned by CRISIL to the bank facilities are disseminated through a variety of channels, including publications and the CRISIL website. CRISIL assigns ratings on the long- and short-term scales, depending on the original maturity of the facility. CRISIL recognises default on term loans on the first instance of a missed payment, while in the case of working capital and non fund-based facilities, default is recognised if the facility remains overdrawn for more than 30 days in a row. CRISIL has been assigning bank loan ratings (BLRs) since June 2007, following Reserve Bank of India (RBI) s announcement of the prudential guidelines for implementation of the new capital adequacy framework for banks, in April These guidelines require banks to link the capital they maintain on credit exposures to the external credit ratings on these exposures. RBI has recognised CRISIL as an eligible external credit assessment institution. Banks can, therefore, use CRISIL s ratings to compute the capital levels they need to maintain on rated credit exposures. Scope and methodology CRISIL rates fund- and non-fund-based facilities extended by banks. This article describes CRISIL s approach to rating bank loans the process followed, the rating scale used for, and the recognition of default on, each type of bank loan facility, and the policy for withdrawal of ratings. This article provides an overview of the criteria and processes used for assigning CRISIL ratings. For detailed criteria and industry-specific parameters used in the assessment of credit risk, refer to the section, Criteria and Methodology, on the CRISIL website. Significance of rating bank loans The Reserve Bank of India (RBI), in its Guidelines for Implementation of the New Capital Adequacy Framework issued in April 2007, had asked foreign banks, and Indian banks with operations outside India, to adopt the standardised approach for credit risk, and the basic indicator approach for operations risk by March 31, All other scheduled commercial banks in India were required to do the same by March 31, In the Basel-II approach, which is an improvement over the Basel-I approach, the credit risk of an exposure is governed by four parameters: the probability of default (PD), the loss-given default (LGD), the exposure at default (EAD), and maturity. Of the four components of credit risk, CRISIL BLRs address the first the PD component. A CRISIL BLR reflects CRISIL s opinion on the likelihood of the financial obligations (arising out of a rated facility) being serviced on time and in full, as specified in the terms of the facility.

2 CRISIL Bank loan ratings process, scale and default definition CRISIL s process for BLRs The process that CRISIL follows (refer to Chart 1) in rating bank loans is similar to the process it follows in rating capital market debt instruments such as bonds, debentures and commercial paper. Chart 1 illustrates CRISIL s rating process for BLRs. Chart 1: Process flow for a rating assignment

3 Dissemination of CRISIL ratings Ratings assigned by CRISIL and accepted by the issuers are disseminated through CRISIL publications and various other media. RBI s guidelines require ratings on bank loan facilities to be available in the public domain, to be eligible for risk-weighting purposes. Additionally, SEBI guidelines require rating agencies to adhere to the International Organisation for Securities Commissions (IOSCO) Code of Conduct, which stipulates that rating agencies publish the ratings along with a report which explains the rationale for the rating opinion. CRISIL disseminates the rating on the bank facilities through its website and updates the rating lists on CRISIL s websites on a real time basis, in addition to publishing the detailed rating report on its website. The impact of security on CRISIL BLRs CRISIL s ratings address Probability of Default, one of the four components of credit risk, as identified under the Basel-II approach. Since lenders usually enforce their security interests only after default has occurred, realisations from assets do not influence the probability of default. For instance, for availing of a letter of credit (LC) facility, companies may offer 10 to 20 per cent of the facility limit as cash margins to the bank. However, the cash margin does not help the bank pre-empt a default by the company. CRISIL, therefore, does not provide any uplift to the facility rating on account of these cash margins. Nevertheless, asset security does have a significant impact on the LGD component of credit risk under the Basel-II approach. The presence of liquid assets on a company s balance sheet does, however, add to its financial flexibility. CRISIL factors this additional financial flexibility into all its BLRs. CRISIL s rating scales for BLRs CRISIL assigns BLRs on the same scales as those it uses in assigning ratings to capital market debt instruments, including bonds, debentures, and commercial paper (refer to Annexure 1). Long- vs short-term rating scale The scale used in assigning a rating to a term loan depends on the loan s original maturity as specified in the terms of the facility. This is in line with CRISIL s approach for assigning ratings to debentures. Also, RBI guidelines specify that a bank facility s maturity is the original contracted maturity, and not residual maturity. Therefore, a term loan with an original contracted maturity of 7 years, for instance, will be rated on the long-term scale, even if the residual maturity is only 8 months. Some fund-based facilities such as cash credit and working capital demand loans (WCDLs) are sanctioned for a period of one year; however, these facilities are often rolled over, and are, thus, akin to long-term exposures from the bank s perspective. CRISIL, therefore, usually assigns ratings to these facilities on the long-term scale. In fact, RBI s guidelines specify that banks use the long-term ratings to compute capital requirement on such exposures. Other fund-based facilities such as packing credit, post-shipment credit, and bill discounting have maturity of less than a year, and are, therefore, rated on the short-term scale. CRISIL assigns ratings to non-fund based facilities such as LC or bank guarantees usually on the shortterm scale. When a bank guarantee is invoked, or an LC devolves on the borrower, the bank makes a payment to the third party on behalf of the borrower. The borrower is required to make good this payment to the bank as per the terms of the bank guarantee facility within a short timeframe. Since the period available for the borrower for repayment is short, these facilities are rated on a short-term scale.

4 CRISIL Bank loan ratings process, scale and default definition Table 1 lists the rating scales that CRISIL follows in rating bank loan facilities. Table 1: Types of Credit Facilities and Rating Scale Applicable Fund-based facilities Rating scale Packing credit Cash credit Long term Working capital demand loan (WCDL) Long term Purchase bill discounting Bill purchase/discounting Factoring/Forfeiting Post-shipment credit Short-term loan Foreign-currency non-resident loan Long term / * Term loans Long term External commercial borrowings (ECBs) Long-term Mortgage loan facility Long-term Vendor financing Short-term Non-fund-based facilities Rating scale Bank guarantee Letter of credit * Based on tenure of loan Banks often sanction credit limits to borrowers, and allow them the flexibility to draw down the limits as one of several pre-determined facilities. In other words, these facilities are fungible between those usually rated on the long-term scale (referred to as a long-term facility) and those rated on the short-term scale (referred to as a short-term facility). In such instances, the portion of the facility that can be drawn down as a long-term facility is assigned a rating on the long-term scale, while the remaining portion is assigned a rating on the short-term scale. CRISIL s approach is in line with RBI s clarification on this issue. Recognition of default on bank loan facilities CRISIL assigns ratings to bank loans as per the terms of the facility, with respect to both repayment amount and repayment date. Consequently, any failure to honour debt obligations as per the terms of the facility is construed as default on the rated facility; this is distinct from the banking norms, where an account is recognised as a non-performing asset (NPA) only when it remains unpaid for more than 90 days after the due date. All facilities in default will carry a rating of CRISIL D on the long-term scale, or the short-term scale. The rating will remain in default category until the arrears are cleared, and a track record of timely repayment is established, subsequently. For term loans, failure to repay the amounts in full on due date is construed as default on the rated facility. Some bank facilities such as cash credit, which do not have specific due dates for repayment, allow borrowers to overdraw on the facility for a specified period with permission from the bank. Though such overdrawing may not necessarily indicate weakening in the borrower s credit quality, banks believe that facilities overdrawn for more than 30 days indicate deteriorating credit quality, and may classify such exposures as potential NPAs. As a result, CRISIL deems cash credit facilities to be in default if they remain overdrawn for more than 30 consecutive days. Similar terms apply for some non-fund based

5 facilities such as bank guarantees. Typically, banks classify non-fund based facilities which remain overdue beyond 30 days as potential NPAs. CRISIL deems these facilities to be in default if the devolved amount remains unpaid for more than 30 days. CRISIL also follows a similar approach to recognition of default for other working capital facilities like packing credit and bill discounting. This is in line with the RBI s guidance to the rating agencies on approach to recognising default on bank loan facilities. Uniform default definition for bank loan facilities prescribed by RBI To ensure that all credit rating agencies follow a common approach for recognising defaults on bank loan facilities rated by them, RBI has prescribed a uniform default definition for bank loan facilities i. For the facilities having a pre-defined repayment date / due date, the definition of one day one rupee may be adhered to ii. For revolving facilities like cash credit, CRAs may allow, as of now, grace period upto a maximum of 30 days from the date of overdrawal, beyond which an entity would be considered to be in default. iii. After the default is cured and the loan facility is regularized, the CRAs should upgrade the rating only if the rated entity shows satisfactory track record for at least 90 days / 3 months from the date of default. Generally in such cases, the rating would move to non-investment grade after curing. Treatment of restructuring and rescheduling CRISIL expects entities that have requested restructuring or rescheduling of their debt obligations to continue to meet interest payment and principal repayment obligations on time and in full, until the lenders formally approve such requests. If borrowers fail to meet debt service obligations on time and in full pending approval of the request, CRISIL will treat such failure as default on the rated facilities. Upon receiving formal lender consent to the restructured terms, CRISIL will use the revised repayment schedule in its future analysis and recognition of default. Withdrawal of ratings A BLR assigned by CRISIL is not a one-time exercise. CRISIL keeps all outstanding ratings, including BLRs under continuous surveillance over the life of the rated facility. CRISIL s policy for withdrawal of ratings stipulates that ratings on facilities (such as term loans), which have scheduled repayment dates, may be withdrawn only on redemption/maturity of the rated facilities. The ratings may also be withdrawn if the rated facilities are pre-paid by the borrower, with the lender s consent, before maturity. For facilities such as cash credit, which do not have a scheduled repayment date, the rating is placed on notice of withdrawal for 180 days, and subsequently withdrawn. CRISIL does not withdraw ratings immediately on request by borrowers; this is because end users of ratings (banks) may face sudden changes in prudential capital requirements, when rated facilities suddenly go to an unrated state.

6 CRISIL Bank loan ratings process, scale and default definition Annexure 1: CRISIL rating scales Long-Term Rating scale Symbol (Rating category) Short-Term Rating scale Symbol (Rating category) Structured Finance Rating scale Long-Term Structured Finance Instruments (Rating category) Short-Term Structured Finance Instruments (Rating category) CRISIL AAA CRISIL A1 CRISIL AAA (SO) CRISIL A1 (SO) CRISIL AA CRISIL A2 CRISIL AA (SO) CRISIL A2 (SO) CRISIL A CRISIL A3 CRISIL A (SO) CRISIL A3 (SO) CRISIL BBB CRISIL A4 CRISIL BBB (SO) CRISIL A4 (SO) CRISIL BB CRISIL D CRISIL BB (SO) CRISIL D (SO) CRISIL B CRISIL C CRISIL B (SO) CRISIL C (SO) CRISIL D CRISIL D (SO) CRISIL may apply '+' (plus) or '-' (minus) signs to ratings from ' CRISIL AA' to ' CRISIL C' to reflect comparative standing within the category; CRISIL may apply + (plus) sign to ratings from 'A1' to 'A4' to reflect a comparatively higher standing within the category. CRISIL may assign rating outlooks to ratings from ' CRISIL AAA' to ' CRISIL B'. Ratings on Rating Watch will not carry outlooks. A rating outlook indicates the direction in which a rating may move over a medium-term horizon of six months to two years. A rating outlook may be 'Positive', 'Stable', or 'Negative'. A 'Positive' or 'Negative' rating outlook is not necessarily a precursor of a rating change. The suffix 'r' indicates investments carrying non-credit risk. The 'r' suffix indicates that payments on the rated instrument have significant risks other than credit risk. The terms of the instrument specify that payments to investors will not be fixed, and may be linked to one or more external variables such as commodity prices, equity indices, or foreign exchange rates. This may result in variability in payments including possible material loss of principal because of adverse movement in the values of external variables. The risk of such adverse movement in price/value is not addressed by the rating.

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8 About CRISIL Limited CRISIL is a global analytical company providing ratings, research, and risk and policy advisory services. We are India's leading ratings agency. We are also the foremost provider of high-end research to the world's largest banks and leading corporations. About CRISIL Ratings CRISIL Ratings is India's leading rating agency. We pioneered the concept of credit rating in India in With a tradition of independence, analytical rigour and innovation, we have a leadership position. We have rated over 60,000 entities, by far the largest number in India. We are a full-service rating agency. We rate the entire range of debt instruments: bank loans, certificates of deposit, commercial paper, non-convertible debentures, bank hybrid capital instruments, asset-backed securities, mortgage-backed securities, perpetual bonds, and partial guarantees. CRISIL sets the standards in every aspect of the credit rating business. We have instituted several innovations in India including rating municipal bonds, partially guaranteed instruments and microfinance institutions. We pioneered a globally unique and affordable rating service for Small and Medium Enterprises (SMEs).This has significantly expanded the market for ratings and is improving SMEs' access to affordable finance. We have an active outreach programme with issuers, investors and regulators to maintain a high level of transparency regarding our rating criteria and to disseminate our analytical insights and knowledge CRISIL Privacy Notice CRISIL respects your privacy. We use your contact information, such as your name, address, and id, to fulfil your request and service your account and to provide you with additional information from CRISIL and other parts of McGraw Hill Financial you may find of interest. For further information, or to let us know your preferences with respect to receiving marketing materials, please visit You can view McGraw Hill Financial s Customer Privacy Policy at Last updated: May, 2013 CRISIL Limited CRISIL House, Central Avenue, Hiranandani Business Park Powai, Mumbai India Phone: Fax: