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Regulatory Governance of Credit Rating Agencies in the EU: The Perils of Pursuing the Holy Grail of Rating Accuracy

Published online by Cambridge University Press:  20 January 2017

Iris H-Y Chiu*
Affiliation:
Faculty of Laws, University College London

Abstract

This paper argues that the EU Regulation of credit rating agencies is concurrently pursuing two objectives that conflict with and would undermine each other. One is the objective of enhancing rating accuracy, and the other is the objective of restoring market discipline in the wholesale investment markets for credit ratings as information goods. The Regulation places more emphasis on regulating for rating accuracy which has the effect of instituting a form of product regulation for credit ratings, raising the public interest profile of credit ratings. This paper argues that this is undesirable and is contrary to policy-makers’ endeavours to enhance market discipline for rating quality and the private accountability of credit rating agencies. EU policy-makers would eventually need to confront the underlying conflicting objectives in the Regulation so that a normatively coherent and consistent regulatory regime can be designed and implemented.

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Articles
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Copyright © Cambridge University Press 2013

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References

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2 Regulation (EC) No 1060/2009 of the European Parliament and of the Council on credit rating agencies (CRA Regulation).

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5 The disadvantages of which are extensively discussed in Fabian Amtenbrink and Jakob De Haan, “Regulating Credit Rating Agencies in the European Union: A Critical First Assessment of Regulation 1060/2009 on Credit Rating Agencies”, 46 Common Market Law Review (2009), p. 1915 et sqq.

6 European Parliament legislative resolution of 16 January 2013 on the proposal for a regulation of the European Parliament and of the Council amending Regulation (EC) No 1060/2009 on credit rating agencies (COM(2011)0747 – C7-0420/2011 – 2011/0361(COD)), hereinafter “CRA Amendment Regulation 2013”.

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21 Many argue that the US SEC's regulation to register only established and tested credit ratings agencies created further barriers to entry for competitors, protecting the incumbents’ oligarchy, see 15 USC § 78o-7 and Manns, Jeffrey, “Rating Risk After the Subprime Mortgage Crisis: A User Fee Approach for Rating Agency Accountability”, 87 North Carolina Law Review (2009), p. 1011 et sqq.Google Scholar

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28 Para 1, Part II, Annex I, Section E. Such information is now collated and provided for public access via ESMA's database CEREP, see <http://cerep.esma.europa.eu/cerep-web/homePage/displayAbout.xhtml> (last accessed on 23 April 2013).

29 Bai provides a detailed analysis of the situations of conflicts of interest that could arise on a personal level for analysts in the rating agency, as well as conflicts of interest that could arise for the agency itself, see Bai, Lynn, “On Regulating Conflicts of Interests in the Credit Rating Industry”, 13 NYU Journal of Legislation and Public Policy(2010), p. 253 et sqq.Google Scholar

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31 Art 11, Para 1, Annex I, Section E.

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38 Goodhart, Charles AE, The Regulatory Response to the Financial Crisis (Cheltenham: Edward Elgar, 2009), at p. 121.Google Scholar

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40 Bai, “On Regulating Conflicts of Interest” (2010), op cit.

41 Proposal for a Regulation of the European Parliament And Of The Council amending Regulation (EC) No 1060/2009 on credit rating agencies (Nov 2011); Proposal for a Directive of the European Parliament And Of The Council amending Directive 2009/65/EC on the coordination of laws, regulations and administrative provisions relating to undertakings of collective investment in transferable securities (UCITS) and Directive 2011/61/EU on Alternative Investment Funds Managers in respect of the excessive reliance on credit ratings (Nov 2011) to clarify that AIFMs and UCITs should not rely solely on credit ratings in their risk management strategies, now adopted in CRA Amendment Regulation, Arts 5a, 5b and 5ab.

42 16 Dec 2010, <http://www.bis.org/bcbs/basel3.htm> (last accessed on 23 April 2013).

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44 Basel Committee, Basel III: A Global Regulatory Framework for More Resilient Banks and Banking Systems (Dec 2010, rev June 2011).

45 Staikouras also argues that a move to internal evaluation models could lead to more information opacity and asymmetry in the market, see Panagiotis K Staikouras, “A Theoretical and Empirical Review of the EU Regulation on Credit Rating Agencies: In Search of Truth, Not Scapegoats”, Financial Markets, Institutions and Instruments (2012), p. 71 et sqq. See “Rating Agencies: Outlook Unchanged”, Financial Times (14 Jan 2013).

46 CRA Amendment Regulation 2013, Art 35a.

47 CRA Amendment Regulation 2013, art 5a.

48 CRA Amendment Regulation 2013, art 35a(1).

49 CRA Amendment Regulation 2013, art 35a(4).

50 Haar however argues that one of the fears surrounding the investor’s civil enforcement action is that investors may see credit rating agency liability as a way out to compensate them for their primary investment loss, see Brigitte Haar, “Civil Liability of Credit Rating Agencies – Regulatory All-or-Nothing Approaches between Immunity and Over-Deterrence” (2012), available on the Internet at <http://ssrn.com/abstract=2198293> (last accessed on 23 April 2013).

51 In the Australian case of Bathurst Regional Council v. Local Government Financial Services [2012] FCA 1200, it could be argued that a few characteristics that made the case successful for the investors against the rating agency would also be established successfully under the CRA Amendment Regulation 2013, art 35a. These are the proximate relationship between the agencies and specifically identified investors giving rise to the reasonable reliance by the investors, the relatively unsophisticated position of the investors in relation to structured finance and the false and misleading nature of the rating which was based on inaccurate information known to the rating agency, which could amount to an ‘intentional’ breach or ‘gross negligence’.

52 European Commission, Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EC) No 106 0/2009 on credit rating agencies (15 November 2011) at <http://ec.europa.eu/internal_market/securities/docs/agencies/COM_2011_747_en.pdf> (last accessed on 23 April 2013).

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57 Financial Services Authority, Product Intervention: Discussion Paper (Jan 2011). This is authorised by section 137C, Financial Services Bill 2012; Article 9(3), ESMA Regulation 2010; Commission proposals for a Directive on markets in financial instruments repealing Directive 2004/39/EC of the European Parliament and of the Council (Oct 2011).

58 CRA Regulation, Recital 23, Art 23.

59 Article 7(2).

60 Para 8, Annex I, Section C.

61 Article 7(3).

62 Article 7(4).

63 Annex I, Section C.

64 Para 1, 2(a) and (b), Annex 1, Section C.

65 Para 2(c), Annex 1, Section C.

66 Para 4, Annex 1, Section C.

67 Para 4, Annex 1, Section B.

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75 Danielle Blanchard and Georges Dionne, “Risk Management and Corporate Governance” (HEC Montreal Risk Management Chair Working Paper, 2003), available on the Internet at <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=441482> (last accessed on 23 April 2013).

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86 Commission Regulation, art 6.

87 Commission Regulation, art 4.

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95 Art 10(5).

96 Art 8(6).

97 ESMA, “Annual Report on the Application Regulation on Credit Rating Agencies as provided by Article 21(5) and Article 39a of the Regulation (EU) No 1060/2009 as amended by Regulation No 1095/2010” (12 January 2012) ESMA/2012/3, available on the Internet at <http://www.esma.europa.eu/system/files/2012-3.pdf> accessed 3 January 2013 (last accessed on 23 April 2013); Commission Regulation.

98 ESMA, “ESMA's Report on the Supervision of Credit Rating Agencies” (22 March 2012), supra note 97. For example, ESMA found less than satisfactory the records kept of internal meetings that are crucial in the lead-up to the issuing of the rating (para 17), the decision- making procedures in internal committees finalising a rating (paras 20, 23), the time pressures under which analysts may be working (para 24), and high staff turnover that may affect rating competence and consistency (para 29).

99 ESMA, Credit Rating Agencies: Annual Report 2012 (March 2013).

100 CRA Amendment Regulation 2013, arts 8b and 8c.

101 above, art 6a.

102 CRA Regulation, art 10(3).

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104 CRA Regulation, Annex I, Part I, Section D, para 1(4) requires credit rating agencies to disclose whether they consider the quality of information used by them to be satisfactory. This however does not amount to a limited or qualified rating, and investors may be unsure of how to treat such disclosures.

105 CRA Amendment Regulation 2013, art 8a.

106 Patrick Jenkins, “Rating Groups could Self–Regulate”, Financial Times(London, 26 June 2012).

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109 Herwig, and Langohr, Patricia, The Rating Agencies and Their Credit Ratings: What They Are, How They Work and Why They are Relevant (Chicester: John Wiley & Sons, 2010) at 111 et sqqGoogle Scholar; Alcubilla, Raquel García and del Pozo, Javier Ruiz, Credit Rating Agencies on the Watch List: Analysis of European Regulation (Oxford: Oxford University Press, 2012) at chapter 1.CrossRefGoogle Scholar

110 Gerding, Erik F, “Code, Crash and Open Source”, 84 Washington Law Review (2009), at p. 127 et sqq.Google Scholar

111 The accountability and liability of ESMA is another issue that affects the question whether ESMA ought to be in the position of governing the governance role of credit rating agencies. This paper will not belabour this for lack of space but see Niamh Moloney, “The European Securities and Markets Authority and Institutional Design for the EU Financial Market – A Tale of Two Competences: Part 2”, 12 European Business Organisation Review (2011), p. 178 et sqq.

112 Buchanan, James M. “An Economic Theory of Clubs”, 32 Economica (1965), pp. 1–14.CrossRefGoogle Scholar

113 Basic v Levinson, 485 U.S. 224 (1988).

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115 Also generally the ‘law matters’ thesis supports civil enforcement as key to strong securities markets. Rafael La Porta, Florencio Lopez–de–Silanes, Andrei Shleifer and Robert W. Vishny, “Legal Determinants of External Finance”, 52 Journal of Finance (1997), p. 1131 et sqq; Rafael La Porta, Florencio Lopez–de–Silanes, Andrei Shleifer, “What Works in Securities Laws” 71 Journal of Finance (2006), p. 1 et sqq; Bernard S Black, “The Legal and Industrial Preconditions for Strong Stock Markets” (Stanford Law School Working Paper No. 179, 2001).

116 A variety of alternative options is discussed in Alcubilla, Raquel García and del Pozo, Javier Ruiz, Credit Rating Agencies on the Watch List: Analysis of European Regulation (Oxford: Oxford University Press, 2012) at chapter 5.1, pp. 246 et sqq.CrossRefGoogle Scholar

117 Lynch, Timothy E, “Deeply and Persistently Conflicted: Credit Rating Agencies in the Current Regulatory Environment”, 59 Case Western Reserve Law Review (2009), p. 227 et sqq.Google Scholar

118 See Chiu, Iris H–Y, “Macro–prudential Supervision: Critically Examining the Developments in the UK, EU and Internationally”, Law and Financial Markets Review (2012), p. 184 et sqq.CrossRefGoogle Scholar

119 Goodhart, Charles AE, The Regulatory Response to the Financial Crisis (Cheltenham: Edward Elgar, 2009) at p. 129 et sqq.Google Scholar

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