Pakistan Credit Securities andExchange …...Management Quality - Here we study the organizational...
Transcript of Pakistan Credit Securities andExchange …...Management Quality - Here we study the organizational...
Pakistan Credit Securities and ExchangePakistan Credit Rating Agency
Securities and Exchange Commission of Pakistan
1Tuesday, September 6, 2011
Regulators…IN ACTIONRegulators…IN ACTION
CRAs, …… , play a critical “gatekeeper” role in the debt market…because of (their) systemic importance and the l l d ( h ) hreliance placed on (their ratings), ….the
activities and performance of CRAs … , are matters of national public interest , as CRAs are central to capital formation, pinvestor confidence, and the efficient performance…of the…economy”
US Congress (Dodd‐Frank Wall Street Reform and Consumer Protection Act, January 5, 2010)
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A New Paradigm…
Dodd Frank
Integrity Skill SetClean Bill of Health…But need improvement
Good….BUT Needs to be Better….
Dodd Frank Act DRIVEN
AccountabilityFocus onEnhanced Focus on
transparencyRegulatory Oversight
A NEW PARADIGM….in the makingRegulatory Oversight CRA Initiatives
CRA Business Model • Separation of ratings from non rating advisory functionsCRA Business Model • Separation of ratings from non‐rating advisory functions• Separation of business solicitation and execution
Governance Structure • Independent directors of the board
Q lit f R ti P A l it i iQuality of Rating Process • Annual criteria review • Training of credit analysts
• Exception recommended where CRA’s size is small 3
Region – An Overview Soveraign Ratings [S&P]
BBB
BBB-
BB+
BB
BBB
BBB-
BB
BB+India
B-
B
BB-
BB
BB-
B
B-
BB
B+ B+
P ki t
Bangladesh
CCC CCC
20102006 2007 2008 2009
Pakistan
Region – NUMBERS SPEAK
N b 2010 2008 2000 2007USA
Numbers 2010 – 2008 2000 – 2007
GDP Growth (Average) 0.4% ~ 3.5%
PakistanGDP Growth (Average) 3.0% 5.5%
NPLs (2010) 14.0% 7.0%
IndiaGDP Growth (%) 8.0% 7.0%
NPLs (%) 2.7% 7.0%
BangladeshGDP Growth (%) 6.0% 5.5%
NPLs (%) 7.9% > 15%4
India – A Proactive regulatory regime for CRAsCRAs
• ROBUST ECONOMY ‐ RATINGS STILL have to face the test of economic distress…..• Significant penetration (CRISIL from less than 1,000 to above 11,000 ratings)• An MoF‐led commission (Dr. K.P. Krishnan Report ‐ Dec 21’09) comprising all stakeholders
KEY Commission Findings – CLEAN BILL OF HEALTH FOR INDIAN CRAs
Area under focus Recommendation
(SEBI, RBI, Industry bodies) sat & deliberated Upon the CRAs…..
Area under focus Recommendation
Regulatory Oversight SEBI (to be the lead regulator) + Standing Committee (having other regulators as members)
Transparency Disclosure of Fee in greater detailTransparency Disclosure of Fee in greater detail
Conflict of Interest Separation of ratings from other CRA businesses
Quality of Rating Process Process & Compliance audits (bi‐annual)Compliance with IOSCO
US CRA regulations in 2007
India – CRA regulations in trast…
.
US – CRA regulations in 2007EU – still in process
place in 1999 –Updated 2010
In Con
t
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Bangladesh – Emphasis on high‐li l i l iquality legislation
• Limited penetration of• The Youngest in the Limited penetration of Ratings…Expected to grow rapidly
The Youngest in the Regional Ratings Industry
•Comprehensive regulations & undertakings
• Enhanced Disclosures
Mandatory Ratings
CRA Ratings for
regulatory
Robust Regulatory Framework
ALL IPOs issued @ premium
Unrated Exposure penalized
purposes
•Regulator driven (SECB + BB)
business volumes
•Regulatory Curbs on Rating
Shopping
Unrated RW” 125%
• All Asset Backed Securities (ABS)
• All Financial Institutions (inInstitutions (in case of an IPO)
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Pakistan – The CRA Default ExperiencePakistan The CRA Default Experience
WHAT made CRA Ratings Falter• Poor Economy
CRA F ll i C di Q liReal GDP Growth (%)
2008 –2011
2004 –2007
< 2.5% 7.25%
CRA – Fall in Credit QualityCRAs 2011 2010 2009 2008 &
BeforeTOTAL
PACRA &
• Stock Market Crash & Closurei idi h i k
Pakistan Economic SurveyPACRA & JCR‐VIS 8 6 1 2 17
• Liquidity crunch in money market• Crumbling Law & Order
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PACRA - SNAPSHOTFirst & Largest Credit Rating Agency of PakistanFirst & Largest Credit Rating Agency of Pakistan
Established in 1994 as JV between IFC, Fitch Ratings and Lahore Stock Exchange.
Ab 1050 ti i i i i tiAbove 1050 rating opinions since inception.
Technical partner for NCR-Bangladesh (National Credit Ratings Limited).
Founding member of ACRAA (Association of Credit Rating Agencies in Asia).g ( g g )
Drafted NBFI’s regulatory and framework for Bangladesh – World Bank assessment
Participate actively in finance related forums – Staff College, LUMS etc.
International Rating for Fitch.
Market share 54% with over 60% share of Corporate and Debt Instruments.
P d t PACRA JCR T t lProducts PACRA JCR Total
Financial Institutions 65 91 156
Corporates 44 29 73
Mutual Funds 62 47 109
Debt Instruments 61 30 91 Ratings penetration: LowDebt Instruments 61 30 91
Total 232 197 429
Ratings penetration: LowCorporates: Very Low
* Note the small size. FIR # 58 not included. 8
1. Organizational Structure
CreditabilityManaging Director
RC (5 members)
2. Staffing
Business ManagementCriteriaR & D2 Rating Teams
2. Staffing Core Team Composition and Expertise
Accountants 10 MBA/MSc 11 BScs 5
Quants• 2 CFAs
Policy Development• 3 dedicated members
• 4 Level-III candidates• 4 Level-II candidates
• Multiple policies developed
Banking Exposure• 2 professional bankers •+50 years cumulative experience • Credit, Risk, CFO, Ops
3. Pecuniary MattersEntity Category
Profitability Loan Size Asset Size Fees
Small <200 <2,000 <4,000 350‐400,000
Medium <500 <5,000 >10,000 400‐450,000
Large <1,000 <10,000 <20,000 400‐600,000
Extra Large >1,000 >10,000 >20,000 600‐750,000
Profitability, Loan size and Asset Size are in PKR mln and fees is in PKR only9
4. Rating Process
PROCESS
Creditability Cont.
Well populated RC
Analytical Team independent of RC
Enhanced documentation
Independent Criteria & Research
Rating Programs
Compliance Audits
Internal Code of Conduct
Compliance Audits
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WHAT WE LOOK AT WHILE EVALUATING A CORPORATE RATING
Creditability Cont.
PACRA arrives at its ratings by evaluating the following factors:
1. Ownership & Governance - Owners credit history –businessacumen & financial strength. Governance structure –distinctionin roles - board oversight - processes to avoid conflict of interest.Transparency and accountability measures.
2 Sponsor Support Sponsors commitment is studied and classified as “Core” Strategic” or “Non2. Sponsor Support - Sponsors commitment is studied and classified as Core Strategic or NonStrategic Investment”. Here we look at the sponsors ability & willingness to provide support intimes of crisis.
3. Management Quality - Here we study the organizational structure, quality of management, itsbili d l i f ibili d ’ bili h istability, delegation of responsibility and management’s accountability mechanism.
4. Systems and Controls - It is constituent of policies & procedures, control mechanism,MIS (Reporting), technology infrastructure. A clue is taken to their appropriateness andeffectiveness.
5. Business Risk- Starting with factors such as current economy, sector performance, entitypositioning, diversification are studied. Then companies’ own strategy of performance isanalyzed.
6 Financial Risk Detailed analysis of company capital structure and cash flows is6. Financial Risk - Detailed analysis of company capital structure and cash flows isundertaken.
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Conflict of Interest
Share holder No interference in the company’s affairs
Board Board – Independent 6 (o/o 7)Board Board Independent 6 (o/o 7)
Rating Committee RC – Independent No shareholder/BoD representationNo reporting to BoDWell Populated RCWell Populated RC
• 3 Apex members[ 2 independent of rating execution process, while 1 is in transition]
• Heads of Rating Teams (2)• Analyst/s
d f i i d• Heads of criteria and R & D (on invitation)
Standard Fee Structure Transparent – in Public domain
Single Business CompanySingle Business Company
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Rating Shopping – Not prevalentRating Shopping Not prevalent
Year Total Switch PACRA to JCR JCR to PACRA
Entity Rating Action Entity Rating Action
National Downgrade
FY2011 2
National Investment Trust
Downgrade (1Notch)
Escort Investment Bank
Downgrade ‐Short Term (1Notch)
IGI FundsUpgrade (2Notches) Asia Insurance
Upgrade (1Notch)IGI Funds (2Notches) Asia Insurance (1Notch)
FY2010 3
House Building Finance Corp Maintain
National Fullerton Asset Mgnt Maintain
JS Investments (AMC)
Downgrade (1Notch) ‐ ‐
FY2009 2
Al‐Baraka Islamic Bank
Upgrade (1Notch) ‐ ‐
Dual Ratings ‐ Current
( No difference in rating opinion between two agencies)1Faysal Bank Limited2The Bank of KhyberFY2009 2
KASB FundsUpgrade(2 Notches) ‐ ‐
y3Askari General Insurance Company Limited4New Jubilee Insurance Company Limited5East West Insurance Company Limited6Pakistan Kuwait Investment Company (Pvt.) Ltd.7Al Baraka Bank (Pakistan) Limited8Tameer Microfinance Bank
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TimelineTimelineTRANSITION TO DEFAULT
(PACRA Defaults)
Key Lifetime Ratings Prior to Default Rating DEFAULT
Entity / Issuers Initial Highest One year Last Financial Institutions
Network Leasing BBB BBB BBB BBB D Network Leasing
(Mar-00) (Mar-00) (Jan-06) (Jan-06 (Oct-06)
First Dawood Investment Bank Limited
BBB (May-98)
A+ (Mar-03)
BBB- (Feb-09)
BB (Nov-09)
D (Dec-09)
Industrial Corporates
D C t Li it dA A BB CC D
Restructured within 90 days
Dewan Cement Limited (Jul-06) (Jul-06) (Dec-08) (May-09) (Nov-09)
Maple Leaf Cement Factory Limited
A (Oct-07)
A (Oct-07)
A- (Dec-08)
BBB- (Dec-09)
D (Dec-09)
Shakarganj Mills Limited BBB+ (Feb 08)
BBB+ (Feb 08)
BBB+ (Feb 08)
BB- (Apr 08)
D (Nov 09)
Under Restructuring
(Feb-08) (Feb-08) (Feb-08) (Apr-08) (Nov-09)
Pace (Pakistan) Limited A+ Jun-07
A+ Jun-07
A (May-10
A (Oct-10)
D (Mar-11)
Azgard Nine Limited A Apr-04
A+ Nov-08
A- (Mar-10)
BB+ (Jun-10)
D (Mar-11)
Under Restructuring Agritech Limited A+ Jun-07
A+ Jun-08
A- (Mar-10)
BB+ (Jun-10)
D (Mar-11)
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Investor Confidence
R‐1 Make Rating Agencies strong Investor ConfidenceR 1 Make Rating Agencies strongR‐1.1 Strengthen oversight and regulationR‐1.2 Critical Size
• Essential for structure
• Transparency• Conflict of Interest• Accountability
• Quality of people
R 2 Conflict of Interest
y• Regulatory Oversight
R‐2 Conflict of InterestR‐2.1 Curb “ratings shopping”R‐2.2 Transparent and equitable fee
R‐3 Self‐regulationR‐3 1 Creation of ACRAA Pakistan ChapterR‐3.1 Creation of ACRAA Pakistan Chapter
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Market DevelopmentThe Fundamental Cannon that must be pursued by markets that aspire to befair, transparent and affording low systemic risk is to ensure that corporatesand businesses desirous of accessing “pubic money” must disclose not onlytheir earnings but also their risk
Disparity in Returns…..??
A h i i b i d d f i l
R‐4 Protection of public interest ‐ Mandatory rating of:
PIBs14%
TAJ Co.
Authentication by independent professionalsEarrings: AuditorsRisk: CRAs
p y g fR‐4.1 New IPOsR‐4.2 Large cap companies (Asset size of over PKR 1bln)R‐4 3 Listed companies
15%
R 4.3 Listed companies
In a phased & progressive manner……
Nos. Company with asset size Within (month)120 > PKR 5,000 mln 18 months225 PKR 500 mln – 5,000 mln 24 months218 < 500 mln 36 months
563
Banks, NBFIs, Funds not included17
Market DevelopmentMarket DevelopmentR‐5 Bond Market expansion
R 5 1 Put optionR‐5.1 Put optionR‐5.2 Stickiness with minimum “A” ratings
R‐6 Legislation in harmony with region
India BangladeshIndia Bangladesh
Higher risk weight (150%)1and loan threshold level
Penalizing unrated exposure with higher risk weight (125%)
R‐7 Mutual Fund Ratings / Rankings
1 Temporarily suspended by RBI as an economy‐stimulating measure. However, expected to be re‐instituted anytime in the near future. Applies to all corporate loans above INR 10mln
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Efficient EconomyEfficient Economy
NewPACRA – One of the few knowledge organizations in P ki
Grants New Markets
Pakistan
PACRA – Ability to f
Referrals to OTHERtake up the role of a
THINK TANKOTHER REGULATORS for developing the Ratings Business
Further expansion & development of CRITERIA; Sector Research
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THE NEXT STEPTHE NEXT STEP….
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Response – SEBI revised guidelines
Q lit fTransparency
• Greater detail
Quality of Rating Process
Transition Studies in
Conflict of Interest
• Code of Conduct
• Greater detail in methodology
Studies in greater detail
• Nature of compensation
• Record keeping
parrangements • Chinese Walls –
Rating solicitation & Production• Ownership
structurestructure
In response to the COMMISSION FINDINGS & RECOMMENDATIONS….SEBI issued revised guidelines for CRAs ‐May 3, 2010 21