Post-default curing period flexibility allows CRAs to upgrade ratings after cure, subject to published policies and oversight. Revision permits CRAs generally to upgrade a cured default to non-investment grade after a 90-day satisfactory performance period, while allowing case-by-case deviations subject to a detailed, published policy. Deviations must be reported to the Ratings Sub-Committee half-yearly with rationale. CRAs must also publish a policy for upgrading defaults to investment grade and may consider scenarios that fundamentally change credit risk, such as technical defaults, management change, acquisition, large long-term fund inflows, or regulatory benefits.
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Provisions expressly mentioned in the judgment/order text.
Post-default curing period flexibility allows CRAs to upgrade ratings after cure, subject to published policies and oversight.
Revision permits CRAs generally to upgrade a cured default to non-investment grade after a 90-day satisfactory performance period, while allowing case-by-case deviations subject to a detailed, published policy. Deviations must be reported to the Ratings Sub-Committee half-yearly with rationale. CRAs must also publish a policy for upgrading defaults to investment grade and may consider scenarios that fundamentally change credit risk, such as technical defaults, management change, acquisition, large long-term fund inflows, or regulatory benefits.
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