Ch09 Counterparty Risk of OTC Derivative.docx

COUNTERPARTY RISK WEIGHTINGS OF OTC DERIVATIVE As stated in the June 1999 Consultative Paper, the 50% ceiling on counterparty risk weightings of OTC derivative transactions will no longer apply. This ceiling was founded on the assumption that counterparties to OTC derivatives contracts tend to be first-class names; this assumption is no longer valid. Furthermore, the increased risk-sensitivity of the new standardized approach renders the ceiling needless. Credit Conversion Factor for Short term Commitments The credit conversion factor for business commitments with original maturity up to one year will be 20% as proposed in the June 1999 Consultative Paper. As an exception, a 0% conversion factor will be applied to commitments that are unconditionally cancellable, or that effectively provide for automatic cancellation, due to deterioration in a borrower’s creditworthiness, at any time by the bank without prior notice. The credit conversion factor for commitments with original maturity over one year will continue to be 50%. Guaranteed Repo-Style Transactions A credit conversion factor of 100% will be applied to the lending of banks. Securities or the posting of securities as collateral by the bank, including instances where these arise out of repo-style transactions (i.e. repo / reverse repo and securities lending/securities borrowing transactions) where the credit converted exposure is secured by eligible collateral. When banks, acting as agents, arrange a repo-style transaction between a customer and a third party and provide a guarantee to the customer that the third party will perform on its obligations, then the risk to the banks is the same as if the banks had entered into a repo-style transaction as principal. In such circumstances, banks would be required to calculate capital requirements as if it were indeed a party to the transaction. Maturity The Committee confirms the view expressed in the June 1999 Consultative paper that, although maturity is one factor that is relevant in the assessment of the credit risk of a claim, it is difficult to pursue greater precision in differentiating among the maturities of claims within the standardized approach given the broad-brush nature of the counterparty risk weighting. The standardized approach is designed to be suitable for application by banks of varying degrees of size and sophistication, and the costs of increasing the complexity of the standardized approach are relatively high. The standardized approach is designed to be suitable for application by banks of varying degrees of size and sophistication, and the costs of increasing the complexity of the standardized approach are relatively high. The Committee has concluded that, in general, the benefits (of improved risk-sensitivity) would be outweighed by the costs (of greater complexity). Despite its improved risk sensitivity, the new standardized approach remains intentionally simple and broad-brush. The Committee has concluded that, in general, the benefits (of improved risk-sensitivity) would be outweighed by the costs (of greater complexity). Despite its improved risk sensitivity, the new standardized approach remains intentionally simple and broad-brush. Therefore, the Committee will not incorporate a maturity dimension throughout the standardized approach. As set out above, the only maturity elements to be included in the standardized approach are the distinction between short-term and long-term commitments, and the distinction between short-term and long-term lending between financial institutions. The other exception is the use of short-term assessments as is discussed below External Credit Assessment The standardized approach draws on external credit assessments for determining risk weights. Therefore, the soundness and reliability of the institutions performing the assessments are vitally important for the new system to be effective. This section discusses the recognition process and the criteria for eligibility. The Recognition Process National supervisors are responsible for determining whether an ECAI meets the criteria listed below. Certain ECAIs may be recognized on a limited basis, e.g. by type of claims or by jurisdiction. Some supervisors may choose to disclose a list of all recognized ECAIs, plus any restrictions which may apply to the use of particular agencies for certain types of exposures. The supervisory process for recognizing ECAIs should be made public to avoid unnecessary barriers to entry. Supervisors will have to gain experience in reviewing and recognising rating agencies in the credit risk area. The Committee thus recognizes the importance for supervisors of sharing their experiences with the use of credit ratings and continuing dialogue with market participants. Objectivity The methodology for assigning credit assessments must be rigorous, systematic, and subject to some form of validation based on historical experience. Moreover, assessments must be subject to ongoing review and responsive to changes in financial condition. Before being recognized by supervisors, an assessment methodology for each market segment, including rigorous back testing, must have been established for at least one year and preferably three. Independence An ECAI should be independent and should not be subject to political or economic pressures that may influence the rating. The assessment process should be as free as possible from any constraints that could arise in situations where the composition of the board of directors or the shareholder structure of the assessment institution may be seen as creating a conflict of interest. International Access / Transparency The individual assessments should be available to both domestic and foreign institutions with legitimate interests and at equivalent terms. In addition, the general methodology used by the ECAI should be publicly available. Disclosure An ECAI should disclose qualitative and quantitative information as set forth below. Disclosures by ECAIs have been designed to ensure that the ratings which banks employ in the allocation of risk weightings are compiled by reputable institutions. An absence of transparency in this context could lead to banks .assessment shopping. For institutions which may give more favourable assessments, leading to misleading indicators of risk exposures and the potential for inadequate capital requirements. Furthermore, such disclosures will underpin the comparability of disclosures across banks. QUALITATIVE DISCLOSURES Qualitative disclosures enable users to compare assessment methods and put quantitative informationinto context. Thus information such as the definition of default, the time horizon, and the target of the assessment are all required. Quantitative disclosures present information on the actual default rates experienced in eachassessment category and information on assessment transitions i.e. the likelihood of an AAA credit transiting to AA etc over time. The disclosure of certain aspects of ECAIs methodologies and definitions is important where differences in methodologies present the opportunity for exploitation by individual banks. The information that needs to be disclosed is presented in more detail in Basel II. The Committee will be carrying out further work on how to make disclosures by ECAIs comparable. Resources An ECAI should have sufficient resources to carry out high quality credit assessments. These resources should allow for substantial on-going contact with senior and operational levels within the entities assessed in order to add value to the credit assessments. Such assessments should be based on methodologies combining qualitative and quantitative approaches. Credibility To some extent, credibility is derived from the criteria above. In addition, the reliance on ECAIs external credit assessments by independent parties (investors, insurers, trading partners) is evidence of the credibility of the assessments of an ECAI. The credibility of an ECAI is also underpinned by the existence of internal procedures to prevent the misuse of confidential information. In order to be eligible for recognition, an ECAI does not have to assess firms in more than one country. Implementation Considerations The mapping process Supervisors will be responsible for slotting ECAIs assessments into the standardized risk weighting framework, i.e. deciding which assessment categories correspond to which risk weights. The mapping process should be objective and should result in a risk weight assignment consistent with that of the level of credit risk reflected in the tables above and should cover the full spectrum of risk weights. These processes also need to be publicly disclosed. Other possibilities for slotting ECAIs assessment categories into the risk framework in an objective manner will be evaluated during the consultation period, for example basing the slotting on experienced default probabilities for individual rating categories of ECAIs. The Committee has begun work in this area and has identified issues such as the definition of default and the types of assessment to be used. Banks must use the chosen ECAIs and their ratings consistently for each type of claim, for both risk weighting and risk management purposes. In other words, banks will not be allowed to cherry-pick the assessments provided by different ECAIs. Banks must disclose on at least an annual basis the credit assessment institutions that they use for the risk weighting of their assets by type of claims, the mapping process determined by supervisors. Other disclosures will also be required, including the percentage of their risk weighted assets that are based on the assessments of each eligible institution. Multiple Assessments If there is only one assessment by an ECAI chosen by a bank for a particular claim, that assessment should be used to determine the risk weight of the claim. If there are two assessments by ECAIs chosen by a bank corresponding to different risk weights, the higher risk weight will be applied. If there are multiple assessments (more than two), the two assessments corresponding to the lowest risk weights referred to, and if they are different, the higher risk weight should be used. If the best two assessments are the same, that assessment should be used to determine the risk weight. Issuer versus Issue Assessment Where a bank invests in a particular issue that has an issue-specific assessment, the risk weight of the claim will be based on this assessment. Where the bank’s claim is not subject to an issue-specific assessment, the following general principles apply. In circumstances where the borrower has a specific assessment for an issued debt but the bank’s claim is not an investment in this particular debt - a high quality credit assessment (one which maps into a risk weight lower than that which applies to an unrated claim) on that specific debt may only be applied to the bank’s unassessed claim if this claim ranks paripassu or senior to the claim with an assessment in all respects. If not, the credit assessment cannot be used and the unassessed claim will receive the risk weight for unrated claims. In circumstances where the borrower has an issuer assessment, this typically applies to senior unsecured claims on that issuer. Consequently, only senior claims on that issuer will benefit from a high quality issuer assessment. Other unassessed claims of a highly assessed issuer will be treated as unrated. If either the issuer or a single issue has a low quality assessment (mapping into a risk weight equal or higher than that which applies to unrated claims), an unassessed claim on the same counterparty will be attributed the same risk weight applicable to the low quality assessment. In order to avoid any double counting of credit enhancement factors, no supervisory recognition of credit risk mitigation techniques will be taken into account if the credit enhancement is already reflected in the issue specific rating. Short Term / Long Term Assessments The Committee intends to carry out further work to consider the feasibility and desirability of using short-term assessments even in cases where there are long-term assessments. In doing so, it will explore the underpinning of the short-term assessments and evaluate the implication of extending the scope of the maturity dimension in this area against the considerations on maturity in general as previously illustrated. As a general rule, if short-term claims receive a 150% risk weight, an unrated unsecured long -term claim should also receive a 150% risk weight, unless the bank uses recognized credit risk mitigation techniques on the long-term claim. THE “INSURED” AND PERSONAL AUTO POLICY BASICS Insurance is a system to protect persons against the risks of financial loss by transferring the risks to a large group who share the financial losses Insurance is based on two principles: risk transference and the law of large numbers. Risk transference, sometimes called ‘pooling’, involves the transfer of risk from the individual to a pool of the insurance company’s policyholders. The insurance company charges a fee, the premium (or part thereof), for accepting the risk and ‘pools’ the premiums from a group of policyholders into a general fund to fund the death benefits under contract. The law of large numbers basically relies on the principle that the larger the pool, the more predictable the amount of losses will be in a given period. Since not all members of the pool are the same age or in the same health condition, we can assume not all of them will be making a claim at the same time. In fact, by recording and studying the number of claims over a very large population, the number of 62 year old men, for example, who will die in a particular year can be fairly predicted. This is not to say the year a particular person will die can be predicted. It only says that in a given year there is a high probability that X number of men who are 62 will die at that age. All insurance is based on these two principles. A teenager commands a higher auto insurance rate because the statistical history has shown they have more accidents and the accidents are more serious than for a 40 year old driver. Homeowners located on the eastern seaboard of Florida have a higher incidence of losses than a homeowner located in Idaho and, statistically, should pay a higher insurance premium. It would not be fair to charge the Idaho homeowner additional fees to cover the costs of hurricanes in Florida, would it? A 40 year old man with two heart by-passes and who smokes statistically has less of a chance of living to age 70 than a 40 year old man who runs marathons. Again, this is not to say there will not be instances of a 40 year old marathon runner dying from heart problems or other causes but, statistically, those incidences will be less for the marathon runner than for the heart patient who smokes. Should both 40 year old men pay the same premium for the same amount of insurance coverage? The application submitted by an applicant is extremely important to the insurance company. The application not only becomes essentially a legal document for purposes of recording what the insurance company knew about the applicant when the insurance company assumed the risk it is very important to the underwriter in rating the insurability of the applicant(s). There are generally rules within the policy to address errors, omissions or falsehoods provided on the application. Insured Risk A risk that meets the following criteria: The insured loss must have a definite time and place; The insured event must be accidental; The insured must have an insurable interest in the subject of coverage; The insured risks must belong to a sufficiently large group of homogeneous exposure units to make losses predictable; The risk must not be subject to a catastrophic loss where a large number of exposure units can be damaged or destroyed in a single event; The coverage must be provided at a reasonable cost; The chance of loss must be calculable. Spread of risk A principle of insurance that insurers need to accept homogeneous exposure units spread over a wide geographic area, with the knowledge that only a given number of risks will result in claims or losses. This dispersion of exposure units allows insurers to project expected losses from the entire body of insured, lessens the potential for catastrophic losses that could occur to exposure units close to each another, and allows for the development of rates. Reduction of risk A method of handling risk by the scope or volume of a firm's operations or through the purchase of insurance. Example: A large outdoor advertising firm reduces its risk of lost revenue due to damaged billboards in a way that a small billboard company cannot because of its large number of dispersed exposure units. The scale of operations makes losses relatively predictable. Insurance reduces risk for the small company by combining a number of similar companies' risks into a more predictable group. What's the difference between an insurance score and a credit score? The use of credit information by insurance companies is not the same as by banks. It's easy to understand how credit applies to getting a bank loan, but insurers aren't as interested in credit-worthiness as in stability. The logic is similar, because while it's not a loan, insurance is like a line of credit. Customers pay premiums so that, in the event of a loss, they will have money to repair or replace their homes, cars, etc. What is a Credit Score? In order to streamline the decision making process, the lending industry has developed a system which scores the borrower's credit history. The score is seen as predictive of the borrower's ability and willingness to repay the loan. Such scoring gives the lender the ability to give the borrower a rapid credit decision by using automated underwriting software currently available. What does my credit score have to do with insurance? Most, if not all, insurance companies use credit scoring as a tool to qualify you for the best premiums possible. It is not a pure credit score, but barometer for estimating your potential for having a claim. Financial history does have an effect on your ability to properly maintain your property. What is an insurance-based credit score? Insurance-based credit score is a number or rating that is generated when information from a consumer's credit history is plugged into a highly specialized insurance formula or rating model. The purpose for selecting and using a consumer's credit information in this manner is to predict the potential risk of loss that consumer poses to the insurance company. How can my credit insurance score benefit me? The way that you manage your credit is very important - it helps determine things like home mortgage interest rates and auto insurance rates. A credit-based insurance score allows insurers to quote the fairest, most appropriate rate for every customer. Our experience shows that about half of our existing customers receive a rate decrease based on credit score. Why do Insurance Companies run a credit score? The use of credit history helps provide a consistent tool to look at every risk. It does not discriminate against any specific group of customers. The results usually help each customer pay his or her fair share of premium for insurance. Is an insurance credit score different from the credit score a bank or financial institution uses? Yes. An insurance credit score differs from the credit score used by banks and financial institutions. Though both scores rely on the same source of information, the scores and the models that generate the scores are designed to predict different outcomes. A bank or financial institution will use credit information (including income) and your credit score to predict the amount of your loan, your ability to repay the loan and the risk that you may default on the loan. Your Credit Score Can Affect Your Car Insurance Rates? You need to understand that your credit history can affect how much you pay for car insurance. Not only can it affect your rates, but it may even impact whether you can get insurance at all — or if insurance companies chooses to renew your policy. If my bank says I have good credit, does that mean I have a good insurance score? Insurers do not look at credit the same way that a financial institution does. Insurers only consider items from your credit report that are relevant to loss potential. A financial institution uses credit to assess credit-worthiness. Is the credit score used by auto insurance companies the same as that used by lenders? No. Lenders use your credit report to estimate your ability to repay a loan. Auto Insurance carriers use a different method to estimate the likelihood or your filing a claim. Some of the issues that may be considered to determine your auto insurance rate include: Analysis of Insurance Contracts Basic Parts of an Insurance Contract Declarations are statements that provide information about the particular property or activity to be insured – Usually the first page of the policy – In property insurance, it contains name of the insured, location of property, period of protection, amount of insurance, premium and deductible information Insurance contracts typically contain a page or section of definitions – For example, the insured is referred to as “you” The insuring agreement summarizes the major promises of the insurer – The two basic forms of an insuring agreement in property insurance are: Named perils policy, where only those perils specifically named in the policy are covered “All-risks” policy, where all losses are covered except those losses specifically excluded May also be called an open-perils policy or special coverage policy Insurers have generally deleted the word “all” from policies “All-risks” coverage has fewer gaps, and the burden of proof is placed on the insurer to deny a claim Insurance contracts contain three major types of exclusions – Excluded perils, e.g., flood, intentional act – Excluded losses, e.g., a professional liability loss is excluded in the homeowners policy – Excluded property, e.g., pets are not covered as personal property in the homeowners policy Exclusions are necessary because: – Some perils are not commercially insurable e.g., catastrophic losses due to war – Extraordinary hazards are present e.g., using the automobile for a taxi – Coverage is provided by other contracts e.g., use of auto excluded on homeowners policy – Moral hazard is present or it would be difficult to measure the amount of loss e.g., coverage of money limited to $200 in homeowners policy – Coverage not needed by typical insureds e.g., homeowners policy does not cover aircraft Conditions are provisions in the policy that qualify or place limitations on the insurer’s promise to perform – If policy conditions are not met, insurer can refuse to pay the claim Insurance policies contain a variety of miscellaneous provisions – e.g., cancellation, subrogation, grace period, misstatement of age PERSONAL AUTO POLICY BASICS The 2005 Personal Auto Policy (PAP) is widely used throughout the USA & European Countries – Drafted by the ISO, it replaces the 1998 form Eligible vehicles include: – A four-wheeled motor vehicle owned or leased by the insured for at least six consecutive months – A pick-up or van with a gross vehicle weight rating of 10,000 pounds or less Cannot be used for deliveries, with some exceptions Autos covered by the policy include: – Any auto shown in the declarations – A newly acquired auto Coverage depends on whether it is an additional vehicle or a replacement vehicle and whether the declarations indicates at least one auto for collision coverage – A trailer owned by the named insured – A temporary substitute vehicle, which is a non-owned auto or trailer used temporarily because of mechanical breakdown, repair, servicing, loss, or destruction of a covered vehicle Liability Coverage Liability coverage is the most important part of the PAP – It protects a covered person against a suit or claim arising out of the ownership or operation of a covered vehicle – The coverage is usually written in split limits, where the amounts of insurance for bodily injury liability and property damage liability are stated separately – The insurer also agrees to provide defense and pay all legal defense costs for claims covered by the policy Defense costs are covered in addition to the policy limits Liability coverage applies to: – The named insured and any resident family member – Any person using the named insured’s covered auto – Any person or organization legally responsible for any insured’s use of a covered auto on behalf of that person or organization – Any person or organization legally responsible for the named insured’s or family members’ use of any auto or trailer (other than a covered auto or one owned by the person or organization). In addition to the policy limits and legal defense, certain supplementary payments can be paid, including: – The cost of a bail bond – Premiums on appeals bonds – Interest accruing after a judgment – Loss of earnings – Other reasonable expenses Exclusions to the coverage include: – Intentional injury or damage – Property owned or transported – Property rented, used, or in the insured’s care – Bodily injury to an employee – Use as a public livery or conveyance – Vehicles used in the auto business – Vehicles with fewer than four wheels – Vehicle furnished for the insured’s regular use If an accident occurs in another state, and the financial responsibility law in that state has higher liability limits than shown in the declarations, the PAP automatically provides the higher limits If more than one liability policy covers a loss: – The insurer pays its pro rata share of the loss for an owned vehicle – The insurance coverage is excess over any other insurance for a non-owned vehicle Medical Payments Medical payments coverage covers all reasonable medical and funeral expenses incurred by an insured in an accident – Two groups are eligible for coverage: The named insured and family members are covered: – While occupying any motor vehicle, or – As pedestrians when struck by a motor vehicle Other persons occupying a covered auto are covered – But not covered in a non-owned vehicle – Covers medical services rendered within three years from the date of the accident – Coverage is not based on fault Exclusions to the coverage include injuries sustained: – While occupying a vehicle with fewer than four wheels – While operating the vehicle as a public livery or conveyance – When the vehicle is used as a residence – When the vehicle is used without a reasonable belief of permission – When the vehicle is competing in a race If more than one auto policy covers a loss: – The insurer pays its pro rata share of the loss for an owned vehicle – The insurance coverage is excess over any other insurance for a non-owned vehicle Uninsured Motorists Coverage The uninsured motorists coverage pays for the bodily injury caused by an uninsured motorist, by a hit-and-run driver, or by a negligent driver whose insurance company is insolvent – In some states, property damage is also covered – The uninsured motorist must be legally liable The coverage applies to: – The named insured and family members – Any other person while occupying a covered auto – Any person legally entitled to recover damages (e.g., a surviving spouse) Coverage does not apply when: – An insured is injured in, or by, a vehicle owned by the named insured, but not insured under the policy – There is primary coverage under another policy – The vehicle is used as a public livery or conveyance Does not apply to a carpool – When workers compensation benefits are applicable There are several limitations when more than one uninsured motorist coverage provision applies to a loss – For example, if an insurer provides coverage on a vehicle not owned by the named insured, the insurance provided is excess over any collectible insurance provided on a primary basis Underinsured motorists coverage can be added to the PAP to provide more complete protection – In general, the maximum amount paid is the underinsured motorist’s coverage limit stated in the policy less the amount paid by the negligent driver’s insurer – Coverage is typically added as an endorsement Some states make it mandatory, while others make it optional Coverage for Damage to Your Auto Under the coverage for damage to your auto, the insurer agrees to pay for any direct and accidental loss to a covered auto or any non-owned auto – Two optional coverages are available: Collision coverage: a collision is defined as the upset of your covered auto or non-owned auto or its impact with another vehicle or object A non-owned auto is also covered under the coverages – A non-owned auto is a private passenger auto, pickup, van, or trailer not owned by or furnished or made available for regular use of the named insured or family member, while it is in the custody of or being operated by the named insured or family member – The coverage also applies to a temporary substitute vehicle The policy offers the broadest coverage applicable to any covered auto shown in the declarations A collision damage waiver (CDW) may be unnecessary on a rental car if you carry collision and comprehensive coverage on your own car – Most independent agents recommend purchase of the CDW This part also pays for temporary transportation expenses, e.g., for train, bus, taxi expenses – The expense must be the result of a covered loss – Coverage is subject to a daily and total limit – Includes charges from a rental car company for loss of daily rental – Coverage for towing and labor costs can be added by an endorsement Exclusions to the coverage include, for example: – Use as a public livery or conveyance – Damage from wear and tear, freezing, and mechanical or electrical breakdown – Radioactive contamination or war – Certain electronic equipment Permanently installed equipment is covered – Tapes, records, and disks – Government destruction or confiscation – Trailer, camper body, or motor home – Racing vehicle For a total loss, the policy pays the actual cash value less the deductible For a partial loss, the policy pays only the amount necessary to repair or replace the damaged property of like kind and quality – The car can be repaired with original equipment manufacturer (OEM) or generic parts Insurers can add a clarifying endorsement to exclude coverage for diminution in value from a direct and accidental physical damage loss – The insured can purchase gap insurance to cover the difference between the amount an insurer pays for a totaled car and the amount owed on a lease or loan If more than one auto policy covers a physical damage loss: – The insurer pays its pro rata share of the loss for an owned vehicle – The insurance coverage is excess over any other insurance for a non-owned vehicle The policy includes an appraisal provision for handling disputes over the amount of physical damage loss – Either party can demand an appraisal of the loss Duties after an Accident or Loss After an accident, the insured is required to perform certain duties, such as: – Promptly notify the insurance company or agent – Cooperate with the insurer in the investigation and settlement of a claim – Send the insurer copies of any legal notices received in connection with an accident – Take a physical exam, if required The police must be notified if a hit-and-run driver is involved The insurer must be allowed to inspect your vehicle if you are seeking coverage under next Part The insurer can deny coverage only if failure to comply is prejudicial to the insurer General Provisions The PAP provides coverage in the US, US territories, Puerto Rico, and Canada All states restrict the insurer’s right to cancel or non-renew coverage Termination provisions include: – Cancellation: The named insured can cancel at any time by returning the policy to the insurer or providing written notice. If a policy has been in force for more than 60 days, the insurer can cancel only if: The premium has not been paid The driver’s license of any insured has been suspended, or The policy was obtained through material misrepresentation – Non-renewal: if an insurer decides to discontinue coverage, the insured must be given notice at least 20 days before the end of the policy period – Automatic termination: a policy is automatically terminated if the insured decline’s the insurer’s offer to renew Insuring Motorcycles and Other Vehicles A miscellaneous-type vehicle endorsement can be added to the PAP to insure motorcycles, mopeds, motor-scooters, golf carts, motor homes, dune buggies, etc. – Does not cover snowmobiles – The liability coverage does not apply to a non-owned vehicle – A passenger hazard exclusion can be elected, which excludes liability for bodily injury to any passenger on a motorcycle COUNTERPARTY RISK WEIGHTINGS OF OTC DERIVATIVE As stated in the June 1999 Consultative Paper, the 50% ceiling on counterparty risk weightings of OTC derivative transactions will no longer apply. This ceiling was founded on the assumption that counterparties to OTC derivatives contracts tend to be first-class names; this assumption is no longer valid. Furthermore, the increased risk-sensitivity of the new standardized approach renders the ceiling needless. Credit Conversion Factor for Short term Commitments The credit conversion factor for business commitments with original maturity up to one year will be 20% as proposed in the June 1999 Consultative Paper. As an exception, a 0% conversion factor will be applied to commitments that are unconditionally cancellable, or that effectively provide for automatic cancellation, due to deterioration in a borrower’s creditworthiness, at any time by the bank without prior notice. The credit conversion factor for commitments with original maturity over one year will continue to be 50%. Guaranteed Repo-Style Transactions A credit conversion factor of 100% will be applied to the lending of banks. Securities or the posting of securities as collateral by the bank, including instances where these arise out of repo-style transactions (i.e. repo / reverse repo and securities lending/securities borrowing transactions) where the credit converted exposure is secured by eligible collateral. When banks, acting as agents, arrange a repo-style transaction between a customer and a third party and provide a guarantee to the customer that the third party will perform on its obligations, then the risk to the banks is the same as if the banks had entered into a repo-style transaction as principal. In such circumstances, banks would be required to calculate capital requirements as if it were indeed a party to the transaction. Maturity The Committee confirms the view expressed in the June 1999 Consultative paper that, although maturity is one factor that is relevant in the assessment of the credit risk of a claim, it is difficult to pursue greater precision in differentiating among the maturities of claims within the standardized approach given the broad-brush nature of the counterparty risk weighting. The standardized approach is designed to be suitable for application by banks of varying degrees of size and sophistication, and the costs of increasing the complexity of the standardized approach are relatively high. The standardized approach is designed to be suitable for application by banks of varying degrees of size and sophistication, and the costs of increasing the complexity of the standardized approach are relatively high. The Committee has concluded that, in general, the benefits (of improved risk-sensitivity) would be outweighed by the costs (of greater complexity). Despite its improved risk sensitivity, the new standardized approach remains intentionally simple and broad-brush. The Committee has concluded that, in general, the benefits (of improved risk-sensitivity) would be outweighed by the costs (of greater complexity). Despite its improved risk sensitivity, the new standardized approach remains intentionally simple and broad-brush. Therefore, the Committee will not incorporate a maturity dimension throughout the standardized approach. As set out above, the only maturity elements to be included in the standardized approach are the distinction between short-term and long-term commitments, and the distinction between short-term and long-term lending between financial institutions. The other exception is the use of short-term assessments as is discussed below External Credit Assessment The standardized approach draws on external credit assessments for determining risk weights. Therefore, the soundness and reliability of the institutions performing the assessments are vitally important for the new system to be effective. This section discusses the recognition process and the criteria for eligibility. Credit Analysis & Risk Management – The Recognition Process National supervisors are responsible for determining whether an ECAI meets the criteria listed below. Certain ECAIs may be recognized on a limited basis, e.g. by type of claims or by jurisdiction. Some supervisors may choose to disclose a list of all recognized ECAIs, plus any restrictions which may apply to the use of particular agencies for certain types of exposures. The supervisory process for recognising ECAIs should be made public to avoid unnecessary barriers to entry. Supervisors will have to gain experience in reviewing and recognising rating agencies in the credit risk area. The Committee thus recognizes the importance for supervisors of sharing their experiences with the use of credit ratings and continuing dialogue with market participants. Objectivity The methodology for assigning credit assessments must be rigorous, systematic, and subject to some form of validation based on historical experience. Moreover, assessments must be subject to ongoing review and responsive to changes in financial condition. Before being recognized by supervisors, an assessment methodology for each market segment, including rigorous back testing, must have been established for at least one year and preferably three. Independence An ECAI should be independent and should not be subject to political or economic pressures that may influence the rating. The assessment process should be as free as possible from any constraints that could arise in situations where the composition of the board of directors or the shareholder structure of the assessment institution may be seen as creating a conflict of interest. International Access / Transparency The individual assessments should be available to both domestic and foreign institutions with legitimate interests and at equivalent terms. In addition, the general methodology used by the ECAI should be publicly available. Disclosure An ECAI should disclose qualitative and quantitative information as set forth below. Disclosures by ECAIs have been designed to ensure that the ratings which banks employ in the allocation of risk weightings are compiled by reputable institutions. An absence of transparency in this context could lead to banks .assessment shopping. For institutions which may give more favourable assessments, leading to misleading indicators of risk exposures and the potential for inadequate capital requirements. Furthermore, such disclosures will underpin the comparability of disclosures across banks