The Basel ii
Accord
From the Basel ii Compliance Professionals Association (BCPA)
the largest association of Basel ii Professionals in the
world
B. External credit
assessment 1. The recognition
process
90. National supervisors are
responsible for determining whether an external credit
assessment institution (ECAI) meets the criteria listed
in the paragraph below.
The assessments of ECAIs may be
recognised on a limited basis, e.g. by type of claims or
by jurisdiction.
The supervisory process for
recognising ECAIs should be made public to avoid
unnecessary barriers to entry.
2. Eligibility
criteria
91. An ECAI
must satisfy each of the following six
criteria.
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 recognised by
supervisors, an assessment methodology for each market
segment, including rigorous backtesting, must have been
established for at least one year and preferably three
years.
Independence: An ECAI should be independent
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 or the shareholder structure of the
assessment institution may be seen as creating a
conflict of interest.
International
access/Transparency: The individual assessments
should be available to both domestic and foreign
institutions with legitimate interests and at equivalent
terms. In addition, the general methodology used by the
ECAI should be publicly available.
Disclosure:
An ECAI should
disclose the following information: 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.
Resources: An ECAI should 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 should be based
on methodologies combining qualitative and quantitative
approaches.
Credibility: To some extent, credibility is
derived from the criteria above.
In addition, the reliance on an
ECAI’s external credit assessments by independent
parties (investors, insurers, trading partners) is
evidence of the credibility of the assessments of an
ECAI.
The credibility of an ECAI is
also underpinned by 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.
C. Implementation
considerations 1. The mapping
process
92. Supervisors will be
responsible for assigning eligible ECAIs’ assessments to
the risk weights available under the standardised risk
weighting framework, i.e. deciding which assessment
categories correspond to which risk weights.
The mapping process should be
objective and should result in a risk weight assignment
consistent with that of the level of credit risk
reflected in the tables above.
It should cover the full
spectrum of risk weights.
93. When conducting such a
mapping process, factors that supervisors should assess
include, among others, the size and scope of the pool of
issuers that each ECAI covers, the range and meaning of
the assessments that it assigns, and the definition of
default used by the ECAI.
In order to promote a more
consistent mapping of assessments into the available
risk weights and help supervisors in conducting such a
process, Annex 2 provides guidance as to how such a
mapping process may be conducted.
94. Banks must use the chosen
ECAIs and their ratings consistently for each type of
claim, for both risk weighting and risk management
purposes.
Banks will not be allowed to “cherry-pick” the
assessments provided by different ECAIs.
95. Banks must disclose 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 supervisors
through the mapping process as well as the aggregated
risk-weighted assets for each risk weight based on the
assessments of each eligible ECAI.
2. Multiple
assessments
96. If there is only one
assessment by an ECAI chosen by a bank for a particular
claim, that assessment should be used to determine the
risk weight of the claim.
97. If there are two assessments
by ECAIs chosen by a bank which map into different risk
weights, the higher risk weight will be
applied.
98. If there are three or more
assessments with different risk weights, the assessments
corresponding to the two lowest risk weights should be
referred to and the higher of those two risk weights
will be applied.
3. Issuer versus
issues assessment
99. Where a bank invests in a
particular issue that has an issue-specific assessment,
the risk weight of the claim will be based on this
assessment.
Where the bank’s claim is not an
investment in a specific assessed issue, the following
general principles apply.
In circumstances where the
borrower has a specific assessment for an issued debt —
but the bank’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 the bank’s unassessed 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 unassessed claim will receive the
risk weight for unrated claims.
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 unassessed 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 unassessed claim on the same
counterparty will be assigned the same risk weight as is
applicable to the low quality
assessment.
100. Whether the bank intends to
rely on an issuer- or an issue-specific assessment, the
assessment must take into account and reflect the entire
amount of credit risk exposure the bank has with regard
to all payments owed to it. *
*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.
101. In order to avoid any
double counting of credit enhancement factors, no
supervisory 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 114).
Domestic currency
and foreign currency assessments
102. 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 would be used for exposures in
foreign currency.
Domestic currency ratings, if
separate, would only be used to risk weight claims
denominated in the domestic currency. *
*
However, when an exposure arises through a bank’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 national supervisory authorities to
be effectively mitigated.
To
qualify, MDBs must have preferred creditor status
recognised in the market and be included in footnote 24.
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.
5.
Short-term/long-term assessments
103. 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 105.
In no event can a short-term
rating be used to support a risk weight for an unrated
long-term claim.
hort-term assessments may only
be used for short-term claims against banks and
corporates.
The table below provides a
framework for banks’ exposures to specific short-term
facilities, such as a particular issuance of commercial
paper

38 * 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-.
39 * This
category includes all non-prime and B or C ratings.
104. 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, should also receive a 150% risk weight,
unless the bank uses recognised credit risk
mitigation techniques for such claims.
105. In cases where national
supervisors have decided to apply option 2 under the
standardised approach to short term interbank claims to
banks in their jurisdiction, the interaction with
specific short-term assessments is expected to be the
following:
• The general preferential
treatment for short-term claims, as defined under
paragraphs 62 and 64, applies to all claims on banks of
up to three months original maturity when there is no
specific short-term claim assessment.
• 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.
When a specific short-term
assessment for a short term claim on a bank maps into a
less favourable (higher) risk weight, the general
short-term preferential treatment for interbank claims
cannot be used.
All unrated short-term claims
should receive the same risk weighting as that implied
by the specific short-term assessment.
106. 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 91 in
terms of its short-term assessment.
6. Level of
application of the assessment
107. External assessments for
one entity within a corporate group cannot be used to
risk weight other entities within the same
group.
7. Unsolicited
ratings
108. As a general rule, banks
should use solicited ratings from eligible ECAIs.
National supervisory authorities
may, however, allow banks to use unsolicited ratings in
the same way as solicited ratings.
However, there may be the
potential for ECAIs to use unsolicited ratings to put
pressure on entities to obtain solicited ratings.
Such
behaviour, when identified, should cause supervisors to
consider whether to continue recognising such ECAIs as
eligible for capital adequacy
purposes.
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