2.4.5 Rating Agencies
Rating agencies updated their rating methodologies of hybrid securities in the light of expanding
contingent capital markets. It is a critical factor to consider when setting the price of contingent
capital instruments. The view of rating agencies is also important for financial strength ratings when
contingent capital becomes sizable in loss absorbency.
Contingent capital instruments that are rated as debt instruments normally receive ratings lower
than investment grade.
Debt Instrument
In 2009, S&P issued a rating criterion for contingent capital. Contingent capital is defined as "debt
and hybrid securities that contain triggers that convert them into equity or some other Tier-1 instrument." 11
11 “Standard & Poor's Ratings Services Criteria Regarding Contingent Capital,” 2.
S&P
believes that the proposed contingent capital increases the risk of loss to the investors, compared to
plain vanilla bonds. Contingent capital securities would receive lower credit ratings than similar ones
without the conversion option. Conversion of capital securities will be treated as default.
Moody's classifies contingent capital into 3 groups: rate, no rate, and may rate. Moody's only rates
"securities that feature triggers for conversion that are credit-linked, objective and measurable and where the impact of
conversion can be estimated.” For triggers that are at the issuer's discretion or unrelated to the financial
condition of the issuers, there will be no rating. When assigning the rating, the major considerations
are "the risk that the ‘host’ security might absorb losses for a ‘going’ concern, and the expected loss severity upon
conversion based on the conversion ratio and the likely value that would be received by investors at that point in time.
Important considerations would include the type and transparency of the trigger, how it is calculated, and over what
time horizon." Moody's is also concerned with contingent capital instruments that have trigger events
based on a regulatory capital ratio. "Because many banks currently operate in rapidly changing regulatory and
political environments, a lack of clarity on legal triggers and an overall resolution framework would prevent Moody’s
from assigning a rating at this time."12
When doing financial analysis, S&P considers a high trigger level and timely conversion critical
for qualifying for an equity instrument, as stated below.
Equity Instrument
"The conversion would need to happen early enough in the issuer's credit deterioration to be able to make a
difference to that decline. A trigger level set at the regulatory capital threshold--or very close to it--is generally insufficient
in our view to warrant equity-like treatment in advance of actual conversion. Similarly, if the conversion mechanisms
allow for a potential significant lag after the trigger breach, we would not view the security as equity-like. Such lags
could arise from stipulated delays or from pragmatic considerations, such as infrequent trigger measurement dates."
10
Moody's determines the amount of equity credit for contingent capital based on their structures.
Moody's thinks that "triggers have generally not proven to be fail-safe in terms of their ability to accurately identify
credit deterioration."
11 It is also difficult to ignore its similarity to debt instruments such as the fixed
coupon rate and the need of refinance after the maturity of contingent capital.
Rating agencies focus on whether the trigger event is clear and objective, and whether it will
result in timely conversion, which is the key to determine its effectiveness of loss absorption.