POLICY FOR APPEAL BY ISSUERS/BORROWERS
(in supersession of policy dated 04th July 2023)
Review Committee
Appeals in respect of Investment Grade (IG) cases would be handled by Rating Review Committee (RRC) while the Non-Investment Grade (NIG) cases would be handled by External Rating Committee (ERC).
Process
- Once the representation/request for review of rating is received from the client, the same shall be reviewed by CRO and the group head concerned for investment grade cases; and any Senior Director and the group head for below investment grade cases, to examine if the criteria as set out below are met and to refer the case to the relevant review committee. If the review criteria are met, the case is referred to the relevant review committee. In case the review criteria are not met, an internal rating committee will consider the same and record the decision with appropriate rationale (in the form of minutes of the meeting).
- In respect of cases referred to the review committee, if there is a specific written request from the issuer as to make personal representation before the Committee, the same may be admitted subject to extant SEBI regulations.
- The agenda for the review committee shall be prepared by the concerned Analytical team who had originally dealt with the case. Thereafter, the review request shall be placed before the relevant Review Committee. The decision of the Review Committee, as the case may be, on the review shall be final and is communicated to the client immediately.
- For fresh (initial) cases, the relevant review committee
shall dispose of the case within 15 days from the date of receipt of appeal. For review / surveillance cases, the request for appeal of rating by issuer need to be received within 3 working days of the Rating Committee meeting. The review committee shall consider such request for review/appeal and the press release in respect of the same shall be published within 7 working days from the date of the rating committee.
Minimum Eligibility Criteria for Review of Cases
- If there is any additional information which was not available/provided at the time of initial rating/ surveillance;
- If there is any new significant development post initial rating/ surveillance.
- If the appeal is not based on additional information and the issuer provides a new perspective on the existing information, then provided point wise mitigating factors or arguments for the key rating factors as provided by the client in its representation are available and, it is different from the analysis captured at the time of the initial rating.
The Review criteria will be applicable for both Surveillance and Fresh cases.
*Policy on Appeal by Issuer/Borrowers (Version VI) is approved in the BM dated 02nd Sept. 2024
