Enhanced disclosure obligations require CRAs to standardize sharp-rating reports, formalize non-cooperation rules and publish machine-readable transparency. CRAs must treat a downgrade of three or more notches between two consecutive rating actions as a sharp rating action and disclose such events including and excluding non-cooperative issuers; adopt detailed INC policies with three consecutive months of non-submission of No-Default Statements as grounds to tag ratings as INC (to be tagged within seven days) while retaining earlier migration discretion; assign ratings in withdrawal press releases except in limited exceptions; permit withdrawal of perpetual debt ratings subject to continuous rating and undertakings from issuer and other CRAs; publish rating transition matrices both excluding and including withdrawn/INC ratings (with withdrawn proportions) and provide machine-readable disclosures with a ten-year archive and separate cumulative default rates including/excluding INCs.
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Provisions expressly mentioned in the judgment/order text.
Enhanced disclosure obligations require CRAs to standardize sharp-rating reports, formalize non-cooperation rules and publish machine-readable transparency.
CRAs must treat a downgrade of three or more notches between two consecutive rating actions as a sharp rating action and disclose such events including and excluding non-cooperative issuers; adopt detailed INC policies with three consecutive months of non-submission of No-Default Statements as grounds to tag ratings as INC (to be tagged within seven days) while retaining earlier migration discretion; assign ratings in withdrawal press releases except in limited exceptions; permit withdrawal of perpetual debt ratings subject to continuous rating and undertakings from issuer and other CRAs; publish rating transition matrices both excluding and including withdrawn/INC ratings (with withdrawn proportions) and provide machine-readable disclosures with a ten-year archive and separate cumulative default rates including/excluding INCs.
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