ECAI ratings

1) For the determination of the risk-weight applicable to an exposure, is a “Bank Deposit Rating” an issue rating as per Article 139 of the CRR? 2) For the determination of the risk-weight applicable to an exposure, should a “Bank Deposit Rating” be used instead of an “Issuer rating” for exposures to institutions which are in the form of deposits (i.e. bank deposits)? What would be the treatment in accordance with Article 139 of the CRR? 3) For instance, which Moody’s rating should be used to risk-weight an exposure to an institution which is in the form of a deposit (i.e. bank deposit): - the “Issuer Rating”? - the “Bank Deposit Rating”? - the “Obligation rating”? - one of the other ratings described in Moody’s methodology? Similar considerations apply to ratings issued by other ECAIs.

According to Article 139 of the CRR, either the issue rating or the issuer rating should be used for the determination of the risk-weight applicable to an exposure. If an issue rating exists as well as an issuer rating, the issue rating should be preferred ( Q&A 652 ). Moreover, the Joint Final draft Implementing Technical Standards on the mapping of ECAIs’ credit assessment under Article 136(1) and (3) of Regulation (EU) No 575/2013 published in November 2015 indicates that the following items are mapped for Moody’s: - Global long-term rating scale - Bond fund rating scale - Global short-term rating scale In addition, Annex 22 of the aforementioned ITS (Mapping of Moody’s Investors Service credit assessments under the Standardised Approach, reference JC 2015 067) further specifies that there are only two Moody’s credit ratings which are relevant to risk-weight exposures to institutions: 1) “Issuer Rating” and 2) “Obligation rating”. Nevertheless, the question arises whether “Bank Deposit Ratings” should be used instead of “Issuer ratings” for exposures to institutions in the form of bank deposits because “Bank Deposit Ratings” are also rated on Moody’s Global rating scale.