The impact of regulatory changes on rating behaviour

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https://www.ecb.europa.eu//pub/pdf/scpwps/ecb.wp2920~f44cdd68b2.en.pdfhttps://www.ecb.europa.eu//pub/pdf/scpwps/ecb.wp2920~f44cdd68b2.en.pdf
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요약
Key Points: 
    • Abstract
      We examine rating behaviour after the introduction of new regulations regarding Credit Rating
      Agencies (CRAs) in the European securitisation market.
    • There is empirical evidence of rating catering in the securitisation market in the pre-GFC period (He et al.,
      2012; Efing and Hau, 2015).
    • Competition among
      CRAs could diminish ratings quality (Golan, Parlour, and Rajan, 2011) and promotes rating shopping by
      issuers resulting in rating inflation (Bolton et al., 2012).
    • This paper investigates the impact of the post-GFC regulatory changes in the European
      securitisation market.
    • In 2011, in addition to the creation of
      European Securities and Markets Authority (ESMA), a regulatory and supervisory body for CRAs was
      introduced.
    • We examine how rating behaviours have changed in the European securitisation market after the
      introduction of these new regulations.
    • We utilise the existence of multiple ratings and rating agreements between
      CRAs to identify the existence of rating shopping and rating catering, respectively (Griffin et al., 2013; He
      et al., 2012; 2016).
    • We find that the regulatory changes have been effective in tackling conflicts of interest between issuers
      and CRAs in the structured finance market.
    • Rating catering, which is a direct consequence of issuer and
      CRA collusion, seems to have disappeared after the introduction of these regulations.
    • There is empirical evidence of rating catering in the securitisation market in
      the pre-GFC period (He et al., 2012; Efing and Hau, 2015).
    • Competition among CRAs could diminish ratings quality (Golan, Parlour,
      and Rajan, 2011) and promotes rating shopping by issuers resulting in rating inflation (Bolton et
      al., 2012).
    • This paper investigates the impact of the post-GFC regulatory changes in the European
      securitisation market.
    • In 2011, in addition
      to the creation of European Securities and Markets Authority (ESMA), a regulatory and
      supervisory body for CRAs was introduced.
    • We find that the regulatory changes have been effective in tackling conflicts of interest
      between issuers and CRAs in the structured finance market.
    • Rating catering, which is a direct
      consequence of issuer and CRA collusion, seems to have disappeared after the introduction of
      these regulations.
    • Investors who previously demanded higher spreads for rating agreements for a
      multiple rated tranche, did not consider the effect of rating harmony as a risk in the post-GFC
      period.
    • Regarding rating shopping, we find that the effectiveness of the changes has been limited,
      potentially for two reasons.
    • Additionally, we also find that rating over-reliance might still be an issue, especially
      Rating catering is a broad term and it can involve rating shopping.
    • They re-examine the rating shopping and rating
      catering phenomena in the US market by looking at the post-crisis period between 2009 and 2013.
    • Using 622 CDO tranches, they also observe the existence of rating shopping and the diminishing
      of the rating catering.
    • Firstly, our main focus is the EU?s CRA Regulation and its effectiveness in reducing
      rating inflation and rating over-reliance.
    • To the best of our knowledge, this paper is the first to
      examine the effectiveness of the EU?s CRA regulatory changes on the investors? perception of
      rating inflation in the European ABS market.
    • Hence, the coverage and quality of our dataset constitutes significant addition
      to the literature and allows us to test the rating shopping and rating catering more authoritatively.
    • The following section reviews the literature
      on securitisation concerning CRAs and conflicts of interest, and outlines the regulatory changes
      introduced in the post-GFC period.
    • Firstly, ratings became ever more important as the Securities and
      Exchange Commission (SEC) 5 began heavily relying on CRA assessments for regulatory purposes
      (i.e.
    • the investment mandates that highlight rating agencies as the main benchmark for investment
      eligibility) (SEC, 2008; Kisgen and Strahan, 2010; Bolton et al., 2012).
    • issuers) as one of the main explanations for the rating inflation (He et al., 2011; 2012; Bolton
      et al., 2012; Efing and Hau, 2015).
    • Bolton et al., (2012) demonstrate that competition
      promotes rating shopping by issuers, leading to rating inflation.
    • The last phase, CRA III, was implemented in mid-2013 and involves an additional
      set of measures on reducing transparency and rating over-reliance.
    • As mentioned above, rating inflation can be caused by rating shopping
      In order to be eligible to use the STS classification, main parties (i.e.
    • The higher the difference in the number of ratings for a
      given ABS tranche, the greater the risk of rating shopping.
    • Alternatively, the impact of the new
      regulations could be limited when it comes to reducing rating shopping.
    • This is because, firstly,
      the conflict of interest between securitisation parties is not necessarily the sole cause for the
      occurrence of rating shopping.
    • L is a set of variables (Multiple ratings, CRA reported, Rating agreement) that
      we utilise interchangeably to capture the rating shopping and rating catering behaviour.
    • Hence, issuers are incentivised to report the highest possible rating and
      ensure each additional rating matches the desired level.
    • All in all, our results suggest that
      the new stricter regulatory measures have been effective in tackling conflicts of interest and
      reducing rating inflation caused by rating catering.
    • Self-selection might be a concern in analysing the impact of the
      new measures and investors? response with regard to the rating inflation.
    • This
      result is in line with the earlier findings suggesting that regulatory changes have reduced investors?
      suspicion of rating inflation and increased trust of CRAs.
    • Conclusion
      Several regulatory changes were introduced in Europe following the GFC aimed at tackling
      conflicts of interest between issuers and CRAs in the ABS market.
    • Utilising a sample of 12,469
      ABS issued between 1998 and 2018 in the European market, this paper examined whether these
      changes have had any impact on rating inflations caused by rating shopping and rating catering
      phenomena.
    • We find that the
      effectiveness of the changes has been more limited on rating shopping potentially for two reasons.
    • Tranche Credit Rating is the rating reported for a tranche at launch.
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