Summary:
Given the important role of credit ratings in mitigating information asymmetry, regulation relies on such ratings, as reflected in regulatory conditions being set based on credit ratings in the bond issuance process. This is manifested in three aspects of the process: first, the issuer needs to provide a credit rating in the bond issuance process; second, the success of bond issuance depends on the credit rating; and third, the issuer is required to provide simultaneously both issuer and facility ratings. Although the regulation requiring credit ratings as a criteria for bond issuance aims to improve issuance quality, it raises a series of issues. First, to meet the requirements for bond issuance, credit ratings are concentrated at specific thresholds. For example, because the regulatory requirement for bond issuance is that the credit rating is not lower than AA, the majority of bonds in the Chinese market are rated AA and above. This is problematic because it leads to insufficient differentiation in credit ratings, which cannot accurately reflect the default risk of issuers. In addition, it can result in credit rating inflation, reducing the quality of credit ratings. The aim of disclosing facility credit ratings and guarantees is not to provide incremental information but to enable issuers to enhance their credit to achieve a higher rating if their initial rating is insufficient, and thus to improve the overall credit rating and increase the success rate of bond issuance. The People's Bank of China clearly pointed out in December 2020 that “problems such as false high ratings, insufficient differentiation and weak pre-warning function have restricted the high-quality development of China's bond market.” In response to these issues, the credit rating regulation policy was adjusted in 2021. On February 26, 2021, the “Management Measures for the Issuance and Trading of Corporate Bonds” were revised, abolishing the mandatory provisions on credit ratings for public issuance of corporate bonds. On March 26, 2021, the “Notice on the Implementation of Arrangements for Canceling Compulsory Ratings of Debt Financing Instruments” pointed out that in the issuance process, the mandatory disclosure requirements for facility rating reports would be canceled, and the disclosure requirements for issuer rating reports would be retained. On August 11, 2021, the People's Bank of China decided to pilot the cancellation of the credit rating requirements for the issuance of non-financial enterprise debt financing instruments. The main purpose of the policy canceling the mandatory facility rating in the issuance process is to change the disclosure of facility credit ratings from mandatory to voluntary. Thus, the policy removes the regulatory role in facility credit ratings but, by retaining issuers' credit ratings, it enables the voluntary disclosure of facility credit ratings to provide incremental information. This paper finds that after the implementation of the mandatory rating policy, the quality of ratings of issuers that retain the facility rating declines, and credit rating quality decreasing is lower when the reputation of the rating agency is high. The heterogeneity analysis shows that the above relationship mainly holds when there is a high degree of competition among rating agencies, the level of customer importance is high, bond issuance is the issuer's initial issuance. Finally, this paper shows that after the implementation of the mandatory facility rating policy, for issuers that retain facility ratings, the inflated credit rating reduces the financing cost of bonds, indicating that the bond market is not fully aware of credit rating inflation, prompting issuers to seek inflated credit ratings. The results of the paper indicate that, on the one hand, the abolition of the mandatory facility rating policy enhances the degree of competition among rating agencies and the motivation of rating agencies to cater to issuers, and thus reduces the quality of credit ratings in the short term. On the other hand, once the selection of a facility rating is made voluntary, the reputation mechanism of the rating market is conducive to a “market-driven” improvement in credit rating quality in the long run.
[1]陈关亭、连立帅和朱松,2021,《多重信用评级与债券融资成本——来自中国债券市场的经验证据》,《金融研究》第2期,第94~113页。 [2]何平和金梦,2010, 《信用评级在中国债券市场的影响力》,《金融研究》第4期,第15~28页。 [3]寇宗来、盘宇章和刘学悦,2015,《中国的信用评级真的影响发债成本吗?》,《金融研究》第10期,第81~98页。 [4]寇宗来、千茜倩和陈关亭,2020,《跟随还是对冲:发行人付费评级机构如何应对中债资信的低评级?》,《管理世界》第9期,第26~39页。 [5]林晚发、刘岩和赵仲匡,2022a,《债券评级包装与“担保正溢价”之谜》,《经济研究》第2期,第192~208页。 [6]林晚发、钟辉勇、赵仲匡和宋敏, 2022b,《金融中介机构竞争的市场反应——来自信用评级机构的证据》,《金融研究》第4期,第77~96页。 [7]宋敏、甘煦和林晚发,2019,《债券信用评级膨胀:原因、影响及对策》,《经济学动态》第3期,第134~147页。 [8]王雄元和张春强,2013,《声誉机制、信用评级与中期票据融资成本》,《金融研究》第8期,第150~164页。 [9]吴育辉、翟玲玲、张润楠和魏志华,2020,《“投资人付费”vs.“发行人付费”:谁的信用评级质量更高?》,《金融研究》第1期,第130~149页。 [10]钟辉勇、钟宁桦和朱小能,2016,《城投债的担保可信吗?——来自债券评级和发行定价的证据》,《金融研究》第4期,第66~82页。 [11]Alp, A., 2013. “Structural Shifts in Credit Rating Standards”, Journal of Finance, 68(6), pp. 2223~2772. [12]Badoer D. and C. Demiroglu, 2019. “The Relevance of Credit Ratings in Transparent Bond Markets”, Review of Financial Studies, 32(1), pp.42~74. [13]Behr, P., D. Kisgen and J. Taillard, 2018. “Did Government Regulations Lead to Inflated Credit Ratings?”, Management Science, 64(3), pp.1034~1054. [14]Becker, B. and T. Milbourn, 2011. “How did increased competition affect credit ratings?”, Journal of Financial Economics, 101 (3), pp. 493~514. [15]Bolton, P., X. Freixas and J. Shapiro, 2012. “The Credit Ratings Game”, Journal of Finance, 67(1), pp. 85~111. [16]Bongaerts, D., K. Cremers and W. N. Goetzmann, 2012. “Tiebreaker: Certification and Multiple Credit Ratings”, Journal of Finance, 67(1), pp. 113~152. [17]Bonsall IV B., K. Koharki and L. Neamtiu, 2022. “The Disciplining Effect of Credit Default Swap Trading on the Quality of Credit Rating Agencies”, Contemporary Accounting Research, 39(2), pp.1297~1333. [18]Dimitrov, V., D. Palia and L. Tang, 2015. "Impact of the Dodd-Frank Act on Credit Ratings”, Journal of Financial Economics, 115(3), pp. 505~520. [19]Dye, R., 2002, “Classifications Manipulation and Nash Accounting Standards”, Journal of Accounting Research, 40(4), pp.1125~1162. [20]Ellul, A., C. Jotikasthira and C.T. Lundblad, 2011. “Regulatory Pressure and Fire Sales in the Corporate Bond Market”, Journal of Financial Economics, 101(3), pp. 596~620. [21]Goldstein, I. and C. Huang, 2020. “Credit Rating Inflation and Firms' Investments”, Journal of Finance, 75(6), pp. 2929~2972. [22]Hand, J.R., R.W. Holthausen and R.W. Leftwich, 1992. “The Effect of Bond Rating Agency Announcements on Bond and Stock Prices”, Journal of Finance, 47(2), pp. 733~752. [23]Healy, M. and K. Palepu, 2001. “Information Asymmetry, Corporate Disclosure, and the Capital Markets: A Review of the Empirical Disclosure Literature”, Journal of Accounting and Economics, 31(1), pp. 405~440. [24]Herpfer, C. and G. Maturana, 2020. “Credit Rating Inflation: Is It Still Relevant and Who Prices It?”, Emory University Working Paper, No. 109461. [25]Jiang, J., M. Stanford and Y. Xie, 2012. “Does It Matter Who Pays for Bond Ratings? Historical Evidence”, Journal of Financial Economics, 105(3), pp. 607~621. [26]Kisgen, D., 2006. “Credit Ratings and Capital Structure”, The Journal of Finance, 61(3), pp. 1035~1072. [27]Kisgen, D., and P. Strahan, 2010. “Do Regulations Based on Credit Ratings Affect a Firm's Cost of Capital?”, Review of Financial Studies, 23(12), pp.4324~4347. [28]Kraft, P., 2015, “Do Rating Agencies Cater? Evidence from Rating-based Contracts”, Journal of Accounting and Economics, 59(2), pp. 264~283. [29]Liu, S. and H. Wang, 2021, “Blessing or Curse: The Real Effects of Rating Inflation”, Tsinghua University Working Paper. [30]Mathis, J.,J. McAndrews and J. Rochet, 2009, “Rating the Raters: Are Reputation Concerns Powerful Enough to Discipline Rating Agencies?”, Journal of Monetary Economics, 56(5), pp. 657~674. [31]Millon, M. and A. Thakor, 1985. “Moral Hazard and Information Sharing: A Model of Financial Information Gathering Agencies”, Journal of Finance, 40(5), pp. 1403~1422. [32]Opp, C., M. Opp, and H. Milton, 2013. “Rating Agencies in the Face of Regulation”, Journal of Financial Economics, 108(1), pp.46~61. [33]Stanton, R., and N. Wallace, 2009. “ABX. HE Indexed Credit Default Swaps and the Valuation of Subprime MBS”, University of California, Berkeley Working Paper. [34]Xia, H. 2014. “Can Investor-Paid Credit Rating Agencies Improve the Information Quality of Issuer-Paid Rating Agencies?”, Journal of Financial Economics, 111(2), pp. 450~468.