Form NRSRO
On September 24, 2007, the U.S. Securities and Exchange Commission granted the registration of Standard & Poor's Ratings Services** as a nationally recognized statistical rating organization ("NRSRO") under the U.S. Credit Rating Agency Reform Act of 2006 (the "Act"). The registration applies to all five of the following classes of credit ratings for which an NRSRO may be registered under the Act:
- financial institutions, brokers, or dealers;
- insurance companies;
- corporate issuers;
- issuers of asset-backed securities;
- and issuers of government securities, municipal securities, or securities issued by a foreign government.
In accordance with the Act, we are making our current Form NRSRO and non-confidential exhibits available on this page.
**Standard & Poor’s Ratings Services changed its name to S&P Global Ratings on April 27, 2016. However, the legacy name may continue to be used for a transitional period.
Exhibit 1
Credit ratings performance measurement statistics. Exhibit 1 is attached and made a part of this Form NRSRO. This Exhibit consists of:
1. Performance measurement statistics consisting of transition and default rates for each class (and applicable subclass) for which S&P Global Ratings is registered as an NRSRO through the most recent calendar year-end for one, three and ten-year periods for the following:
- Financial Institutions, Brokers, or Dealers
- Insurance Companies
- Corporate Issuers
- Issuers of Asset-Backed Securities (RMBS, CMBS, CLO, CDO, ABCP, other ABS, other Structured Finance)
- Sovereign Issuers
- U.S. Public Finance
- International Public Finance
2. Credit rating definitions of the designations used to distinguish the creditworthiness of rated obligors, securities and money market instruments.
3. History of Rating Actions
In accordance with the rules of the Securities and Exchange Commission (the "Commission"), the NRSRO makes and keeps publicly available on its internet website in an interactive data file in XBRL format the ratings action information required pursuant to 17 CFR §240.17g-7(b), at the following URL:
https://disclosure.spglobal.com/ratings/en/regulatory/ratingshistory
4. Method of Calculating Performance Measurement Statistics
Exhibit 2
A description of the procedures and methodologies used in determining credit ratings. Exhibit 2 is attached and made a part of this Form NRSRO.
The following documents attached below describe the procedures and methodologies used in determining credit ratings.
Note: Capitalized terms used but not defined in the policies below generally will have the meanings assigned in the Glossary of Terms included within this Exhibit.
Principles of Credit RatingsGlossaryGeneral Description of the Credit Rating ProcessAssignment of Credit Ratings Withdrawal, Discontinuance, and Suspension Sufficient Information (Quality of Information) Rating Committee Issuer Notification (including Issuer Appeals) Ratings Release Surveillance Error Correction Prohibited Activities Model Use Methodology Ratings Vendor Management Analysis of Information and Application of CriteriaExhibit 3
Policies or procedures adopted and implemented to prevent the misuse of material, nonpublic information. Exhibit 3 is attached and made a part of this Form NRSRO.
Note: Capitalized terms used but not defined in the policies below generally will have the meanings assigned in the Glossary of Terms included within Exhibit 2 to this Form NRSRO.
S&P Global Code of Business Ethics for EmployeesDivisional Independence and ObjectivityS&P Global Ratings Code of Conduct*S&P Global Ratings Code of Conduct--Australia*Securities Disclosure and Trading PolicyRatings Addendum to Securities Disclosure and Trading PolicyOutside Activities Professional Conduct PolicyAvoiding Selective Disclosure of Material Non-Public InformationManaging Confidential InformationRatings ReleaseIssuer Notification (including Issuer Appeals)Corporate Governance* To meet local regulatory requirements, a Code of Conduct is in effect in Australia in addition to the global Code of Conduct.
Exhibit 4
Organizational structure. Exhibit 4 is attached to and made a part of this Form NRSRO. SPGI's operations are described below.
Description of the BusinessAttached below are:
(1) SPGI Subsidiary List - subsidiaries of S&P Global Inc.(2) NRSRO Organization ChartsExhibit 5
The code of ethics in effect at the credit rating agency or a statement of the reasons why the credit rating agency does not have a code of ethics. Exhibit 5 is attached and made a part of this Form NRSRO.
Note: Capitalized terms used but not defined in the policies below generally will have the meanings assigned in the Glossary of Terms included within Exhibit 2 to this Form NRSRO.
S&P Global Ratings Code of Conduct*S&P Global Ratings Code of Conduct--Australia*S&P Global Code of Business Ethics for EmployeesSecurities Disclosure and Trading PolicyRatings Addendum to Securities Disclosure and Trading PolicyOutside Activities Professional Conduct Policy* To meet local regulatory requirements, a Code of Conduct is in effect in Australia in addition to the global Code of Conduct.
Exhibit 6
Identification of conflicts of interests relating to the issuance of credit ratings. Exhibit 6 is attached to and made part of this Form NRSRO.
Identification of Conflicts of Interests Relating to the Issuance of Credit RatingsExhibit 7
Policies and procedures to address and manage conflicts of interest. Exhibit 7 is attached to and made a part of this Form NRSRO.
Note: Capitalized terms used but not defined in the policies below generally will have the meanings assigned in the Glossary of Terms included within Exhibit 2 to this Form NRSRO.
S&P Global Code of Business Ethics for Employees S&P Global Ratings Code of Conduct* S&P Global Ratings Code of Conduct--Australia* Divisional Independence and Objectivity Securities Disclosure and Trading Policy Ratings Addendum to Securities Disclosure and Trading Policy Outside Activities Professional Conduct Policy Avoiding Selective Disclosure of Material Non-Public Information Roles and Responsibilities Prohibited Activities Gifts, Entertainment, Conferences and Other Events Analyst Rotation Ancillary Services & Other Services Avoiding Conflicts with Ancillary and Other Services Potential Business Relationship Look-Back Review Rating Committee Complaint Report Illegal Conduct, No Retaliation Secure Website--SEC Rule 17g-5 Corporate Governance Market Interaction US Presentation of Credit Ratings Disclosure Recordkeeping & Retention* To meet local regulatory requirements, a Code of Conduct is in effect in Australia in addition to the global Code of Conduct.
Exhibit 8
Certain information regarding the credit rating agency's credit analysts and credit analyst supervisors. Exhibit 8 is attached to and made a part of this Form NRSRO.
Note: Capitalized terms used but not defined in the document below generally will have the meanings assigned in the Glossary of Terms included within Exhibit 2 to this Form NRSRO.
Information on credit analysts and credit analyst supervisorsThe documents attached below further describe the resourcing, training, experience, and competency policies with respect to credit analysts.
Sufficient Resources Standards of Training, Experience and CompetenceExhibit 9
Certain Information Regarding the Credit Rating Agency's Designated Compliance Officer. Exhibit 9 is attached to and made a part of this Form NRSRO.
Certain Information Regarding the Credit Rating Agency's Designated Compliance Officer