Reducing Reliance on Credit Rating Agency (CRA) Ratings Action Plan Singapore. Reducing References to CRA Ratings in Laws and Regulations

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1 Reducing Reliance n Credit Rating Agency (CRA) Ratings Actin Plan Singapre A Reducing References t CRA Ratings in Laws and Regulatins 1 As part f the FSB thematic review n reducing reliance n CRA ratings, the Mnetary Authrity f Singapre (MAS) 1 updated its stcktake f references t credit ratings in dmestic laws and regulatins in The stcktake did nt reveal substantial hardwiring f credit ratings in legislatin beynd what is already prescribed in internatinal standards. The identified references were assessed t be unlikely t encurage mechanistic reliance by financial institutins. Central Bank Operatins 2 There is minimal reliance n CRA ratings in central bank peratins carried ut by MAS. Our liquidity facilities mainly accept Singapre gvernment securities and MAS bills, while ur risk management framewrk fr reserves management cnsiders a wide range f inputs fr the assessment f credit risk, including market based indicatrs (e.g. CDS spreads) and qualitative factrs (e.g. parental and gvernment supprt). Regulatin and Supervisin 3 Where references t credit ratings are present, MAS has taken steps t ensure that the references t credit ratings are generally accmpanied by caveats that ratings are nt sufficient in and f themselves and shuld be accmpanied by apprpriate credit assessments. This aims t reduce verreliance n credit ratings by financial institutins. Banking and capital markets intermediaries. Fr regulatry capital cmputatin, Singapre-incrprated banks, merchant banks and capital markets services licensees are required t perfrm an apprpriate level f due diligence prir t the use f any recgnised external credit assessment institutin (ECAI). They are als expected t assess whether regulatry risk weights applied are apprpriate fr the risk f the expsure, and cnsider any higher degree f credit risk in their evaluatin f verall capital adequacy. These requirements are set ut in the relevant rules, e.g. MAS Ntice 637 (paragraph 7.3.3A, paragraph 3.3 f Annex 10A), MAS Ntice 1111 (paragraphs 7.3.3A and 7.3.4A) and MAS Ntice SFA 04- N13 (paragraph 3 f Annex 5A). 1 The Mnetary Authrity f Singapre is the integrated regulatr f banking, insurance and securities in Singapre. The MAS is respnsible fr develping and executing the actin plan. 1

2 Securities. MAS Cde n Cllective Investment Schemes (CIS) includes sme references t credit ratings. Accrdingly, MAS amended the Cde in 2011 t explicitly stress that a CIS peratr shuld nt rely slely r mechanistically n ratings issued by credit rating agencies. Where pssible, the CIS peratr shuld make its wn credit assessments t verify ratings issued by CRAs. Where the credit rating differs frm the CIS peratr s internal assessment, the mre cnservative rating shuld be adpted. This is intended t ensure that CIS peratrs take a prudent apprach (and cnsider the factrs that culd have caused the lwer ratings) when making investment decisins r selecting cunterparties 2. 4 In sme areas, mst ntably bank capital adequacy and liquidity cverage rules, references t credit ratings in dmestic rules are tied t their presence in internatinal standards, i.e. the BCBS Standardised Appraches. As at the end f September 2013, 1 ut f the 4 Singapre incrprated banking grups 3 and all 34 Singapre-incrprated merchant banks 4 use nly the Standardised Apprach fr credit risk. Overall, 19.3% f the ttal riskweighted assets f the lcally incrprated banking grups and merchant banks are cvered by the Standardised Apprach fr credit risk. 5 Taking int cnsideratin the wrk that has already been dne, MAS has identified the fllwing key areas fr further actin: Actin a. Use f ratings in bank capital adequacy requirements. Ratings frm external credit assessment institutins (ECAIs) are used fr the purpse f regulatry capital cmputatin, in line with the Basel Cmmittee n Banking Supervisin s (BCBS) recmmendatins under the Basel capital rules. Timeline Internal review f dmestic rules t be cmpleted 6 mnths after BCBS Task Frce n Standardised This apprach recgnises that there culd be situatins where the credit rating agencies are better placed than the CIS peratr t undertake credit assessments, e.g. where the peratr des nt have access t pertinent infrmatin t accurately assess the credit risk f an investment. Cnversely, in ther situatins, the peratr may be in a better psitin t undertake the credit assessment, e.g. where the peratr has an in-depth understanding f the lcal markets and cnditins. CIS peratrs are bliged t give due cnsideratin t bth internal and external ratings, as well as the cntributing factrs tward any differences between the tw, and adpt the mre prudent rating. The 3 Singapre-incrprated banking grups adpt a partial use f the Standardised Apprach fr credit risk. Merchant banks are a class f financial institutins licensed and supervised under the MAS Act. They have mre specialised business mdels such as capital market activities (e.g. crprate finance) and wealth management activities. The 34 Singapre-incrprated merchant banks accunt fr 4.2% f ttal assets f the banking system in Singapre. 2

3 Banks are already required t perfrm an apprpriate level f due diligence prir t the use f the ratings by a recgnised CRA, and expected t assess whether the regulatry risk weight applied is apprpriate fr the risk f the expsure. Where the IRB apprach has been adpted, MAS will cntinue t ensure that the banking grup uses the apprach fr a meaningful prprtin f credit expsures acrss the entire banking grup. Further prgress in remving references t credit ratings in bank capital adequacy requirements hinges upn the wrk f the BCBS Task Frce n the Standardised Appraches, which is currently under way. As a BCBS member, MAS will take guidance frm the Basel review upn its cmpletin. Appraches publishes its recmmendatins. Legislative changes, if any, t be issued within 1 year after the cmpletin f the internal review. b. Use f ratings in the rules n expsures t single cunterparty grups fr banks. Currently, certain expsures (e.g. expsures t AAA-rated svereigns and public sectr entities) are treated as exempt expsures fr the purpse f cmpliance with the large expsure limits. MAS will take guidance frm the BCBS review n an internatinally harmnised large expsures framewrk. Amendments will be made t references n the use f CRA ratings accrdingly. A plicy review f dmestic rules t be cmpleted 12 mnths after BCBS cmpletes its review n the large expsures framewrk. c. Use f ratings in Cde n Cllective Investment Schemes. Under the Cde n Cllective Investment Schemes, cllective investment schemes cnstituted as prperty funds are subjected t a 35% leverage limit, which can be raised t 60% if the fund btains a credit rating and disclses such ratings t the public. MAS is reviewing this requirement, and any prpsed change will be put up fr public cnsultatin in late 2013/2014. Public cnsultatin in B Strengthening credit assessment capabilities 6 As nted in the FSB s September 2013 status reprt t G20 Leaders n prgress in reducing reliance n credit ratings and strengthening versight f CRAs, the develpment f market participants internal risk assessment systems is frequently cnstrained by resurce requirements and the relative scarcity f expertise in credit risk analysis. 3

4 7 In line with the FSB radmap fr reducing reliance n CRA ratings, MAS has als taken measures t strengthen the credit assessment capabilities f market participants. These include: Banking. Singapre-incrprated banks are required t cmply with the public disclsure requirements prescribed under Pillar 3 f the Basel capital framewrk. At the brad level, a bank is required t disclse: its credit risk strategies and prcesses; the structure and rganisatin f the credit risk management functin; the scpe and nature f its risk reprting and measurement systems; and its plicies fr hedging and mitigating risk, and prcess fr mnitring the cntinuing effectiveness f such plicies. Disclsure requirements with respect t internal credit risk assessment prcesses include: the rle played by CRA ratings in internal credit risk assessment prcesses (e.g. the types f expsure fr which ratings f each CRA are used); the structure f internal rating systems and the relatinship between internal and external ratings; the prcess fr managing and recgnising credit risk mitigants; and the cntrl mechanisms fr the rating system including independence, accuntability, and rating system review. Insurance. MAS requires direct insurers t have in place a risk management strategy setting ut clear methdlgies and assessments t justify its selectin f reinsurers and reinsurance arrangements, with credit ratings nly ne factr in the assessment. Securities. MAS has intrduced a requirement fr the prspectus f assetbacked securities t disclse any frm f due diligence (including any review, verificatin, r assessment) in respect f underlying assets that has been perfrmed by the issuer, spnsr, riginatr, underwriter r any third party. The bjective f this rule is t encurage parties invlved in the ffer t cnduct mre careful due diligence and risk assessment (including credit risk assessment) n underlying assets. Central cunterparties (CCPs). There are currently tw systemically imprtant CCPs in Singapre, namely, the Singapre Exchange Derivatives Clearing Limited and the Central Depsitry. MAS requires CCPs t have in place credit assessment prcesses in respect f their cllateral plicies and supervisin f 4

5 members, and nt rely slely n credit ratings 5. Any changes t CCP risk management practices are subject t MAS review and apprval. The 2013 IMF FSAP had assessed bth CCPs clearing and settlement infrastructures as sund and efficient, with effective risk management framewrks. 8 As nted in the FSB s September 2013 status reprt t G20 Leaders n CRArelated initiatives, the develpment f firms internal risk assessment systems is frequently cnstrained by resurce requirements and the relative scarcity f expertise in credit risk analysis. Hence, MAS will encurage market participants t enhance their credit risk assessment capabilities. In ding s, MAS will aim t ensure that market participants credit risk management prcesses are rbust and cmmensurate t the scale and cmplexity f their peratins. Actin Timeline a. Engaging financial institutins. On an nging basis and as apprpriate, MAS will wrk with industry n enhancing their credit assessment capabilities thrugh several channels: Onging i. On-site inspectin and ff-site supervisry review f credit risk assessment prcesses t ensure that they are rbust and d nt place undue reliance n credit ratings. Areas fr imprvement in the credit assessment prcesses and gd credit underwriting practices bserved frm inspectins will be shared with the respective financial institutins and the industry where apprpriate. ii. iii. Encuraging regular review f the use f CRA ratings in investment plicies, guidelines and mandates f investment managers and regulated institutinal investrs (e.g. insurers), n a supervisry basis. Regular and adequate industry wide stress testing f banks and insurers t determine that financial 5 Fr instance, CCPs cnduct internal assessments t ensure that nly quality cllateral with lw credit, liquidity and market risks are accepted, and apply cnservative haircuts accrdingly. Assessments f credit risks include mnitring fr any adverse news r develpments in relatin t the particular cllateral. CCPs als d nt currently invest cllateral psted with them. With respect t supervisin f members, CCPs have ther membership criteria, such as financial, peratinal and legal requirements t ensure that admissin criteria and nging requirements are risk-based and cmmensurate with risks undertaken by members. 5

6 institutins take apprpriate remedial r risk mitigatins where warranted n their ptential expsure t credit risk arising frm adverse market cnditins. iv. Prmulgatin and peridic update f guidelines n sund practices in credit risk management. The guidelines cver varius aspects f the credit lifecycle, with a view t ensuring that financial institutins plicies, prcesses and practices are sund and result in a prperly cntrlled credit risk envirnment. v. Regular dialgue with industry thrugh firm-specific and rundtable discussins t understand challenges faced in building independent credit risk assessment systems. b. Enhancing disclsures t investrs. Our securities ffering regime is geared twards prmting effective disclsure thrugh imprving the quality f infrmatin given t investrs s as t equip investrs t make infrmed investment decisins. (i) (ii) Even thugh ur current regime des nt place undue reliance n credit ratings, MAS plans t amend existing regulatins t imprve the quality f infrmatin given t investrs. Where a credit rating is disclsed in a prspectus, the prspectus must (i) explain the meaning, functin and limitatins f the credit rating, including the fact that it is a statement f pinin (ii) state that the rating is nt a recmmendatin t invest in the securities, and (iii) state that the rating is current as at the date f registratin f the prspectus and subject t revisin r withdrawal at any time. We expect t effect this amendment by 1Q In additin, the Cde n Cllective Investment Schemes currently states that the manager shuld nt rely slely and mechanistically n ratings issued by credit rating agencies and shuld perfrm its wn internal credit assessment t verify these ratings. MAS will cnsult n a prpsal t require the CIS manager t disclse in the prspectus the credit risk Effected by 1Q 2014 Public Cnsultatin in

7 assessment practices that it has adpted fr the purpses f verifying the ratings issued by credit rating agencies. The infrmatin t be disclsed culd include the scpe f the assessment, the extent t which it will rely n ratings issued by credit rating agencies and ther tls/metrics that will be used in the internal credit assessment. This disclsure requirement will encurage CIS peratrs t put in place rbust credit risk assessment practices as investrs are less likely t invest in CIS where the disclsure shws that the scpe and extent f the credit risk assessment practices f the CIS peratrs are inadequate. We aim t cnduct a public cnsultatin n this prpsal in c. Taking guidance frm internatinal standard setters n issues such as alternative standards f creditwrthiness and ways t strengthen market participants credit assessment capabilities. We will review internatinal guidance as it is issued, with a view t incrprating it int ur supervisry apprach where apprpriate. Onging 7

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