showing the amendment adopted on june 11, 2018 by the …...the task force considered holding a...

Attachment C

Valuation of Securities (E) Task Force

6/11/18

© 2018 National Association of Insurance Commissioners 1

MEMORANDUM

TO: Kevin Fry, Chair, Valuation of Securities (E) Task Force

Members of the Valuation of Securities (E) Task Force

FROM: Bob Carcano, Senior Counsel, NAIC Investment Analysis Office;

CC: Charles Therriault, Director, NAIC Securities Valuation Office;

Eric Kolchinsky, Director, NAIC Structured Securities Group

Julie Garber, NAIC Senior Manager, Accreditation

DATE: December 28, 2017

RE: Proposed Amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (P&P

Manual) –Definitional Changes and Mapping Framework for an Expanded NAIC RBC Framework

Showing the Amendment Adopted on June 11, 2018 by the VOS TF

and as revised on Aug. 5, 2018

1. Introduction - The Investment Risk-Based Capital (E) Working Group has adopted a proposal to increase the

number of risk-based capital (RBC) categories for bonds to 20 based using credit rating default probabilities of NAIC CRPs.

The Task Force received the Working Group’s proposal at the 2016 Fall National Meeting and directed SVO and SSG to

evaluate the proposal and provide recommendations. The IAO presented its report on April 9, 2017 which was subsequently

adopted on Aug. 7, 2017 and referred to the Working Group.

2. Discussion - The IAO report outlined the staff’s intent to create an NAIC Designation Category as the framework

the Working Group would use to assign more granular RBC factors linked to the prevailing NAIC Designation framework.

The new NAIC Designation Category would apply to NAIC Designations produced by the SVO, independently or based on

CRP credit ratings for filing exempt and PL securities as well as those assigned to RMBS and CMBS based on financial

modelling by the SSG or other structured securities subject to the modified filing exempt process. During the Aug. 7 meeting,

the Task Force considered holding a joint conference call with the Working Group and the Capital Adequacy (E) Task Force

to consider adoption of the proposed RBC framework. That meeting could not be arranged as initially thought although the

target implementation date is still Jan. 1, 2019 for insurer reporting by year-end Dec. 31, 2019. The IAO therefore proposes

the amendments to the P&P Manual shown below. The amendments weave the NAIC Designation Category concept into that

of NAIC Designations and provide for mapping of NAIC CRP credit ratings to the RBC factors. Adoption of these

amendments early in 2018, would permit the staff to develop and implement administrative, technology and operational

Attachment C


6/11/18


components for the new process as well as develop any new process that may be required for filing or reporting purposes.

The IAO recommends that the Task Force make the amendments effective Jan. 1, 2019 with the understanding the

implementation could be moved if all necessary components are not in place by that time.

3. Proposed Amendment –The proposed amendments shown below describe and explain the purpose of NAIC

Designation Categories and their relationship to NAIC Designations and provide additional mapping tables for use in the

NAIC RBC process along those now used to produce NAIC Designations for filing exempt and PL securities.

Text Revised

to Show Correction of Edits Noted in ACLI/NASVA Comment Letter

Changes Identified by Comment Balloons KM 1 et seq. dated June 4, 2018.

Part One Purposes, General Policies and Instructions to the SVO

Section 2 – Policies Defining the SVO Staff Function

(b) SVO Regulatory Products

(i) NAIC Designations

The result of SVO's credit analysis, as it pertains to credit risk (hereafter defined), shall be

expressed as an opinion of credit quality by assignment of an NAIC Designation, notched to

reflect the position of the specific liability in the issuer’s capital structure. Collectively, NAIC

Designations categories, defined in Part One, Section 3 b) (i) of this Manual, describes a credit

quality-risk gradation range from highest quality (least risk) to lowest quality (greatest risk).

Subject to the application of Part One, Section 2(f) of this Part, NAIC Designations express

opinions about credit risk except when accompanied by the NAIC Designation subscript,

described in paragraph (iii) below.

Credit risk is defined as the relative financial capability of an obligor to make the payments

contractually promised to a lender. Credit analysis is performed solely for the purpose of

designating the quality of an investment made by an insurance company to enable the NAIC

member's department of insurance to determine regulatory treatment.

Credit risk is determined by analyzing the information and documentation provided to the SVO

by the reporting insurance company and its advisors. The SVO does not audit the information

submitted and assumes the information to be timely, accurate and reliable.

The ability of an insurance company to realize payment on a financial obligation can be affected

by factors not related to credit risk or by the manner in which the repayment promise has been

structured.

NAIC Designations do not measure other risks or factors that may affect repayment, such as

volatility/interest rate, prepayment, extension or liquidity risk.

An NAIC Designation must be interpreted by the NAIC member in context of the NAIC

Financial Conditions Framework, other characteristics of the investment, and the specific

regulatory status of the insurance company.

Attachment C


6/11/18


The result of SVO's credit analysis, expressed as an opinion of credit quality by assignment of

an NAIC Designation shall be further expanded into NAIC Designation Categories as, and for

the purposes, discussed in Part One, Section 3 b) (i) of this Manual.

…

Section 3 Internal Administration

(b) Definitions of NAIC Designation, NAIC Designation Categories, Valuation Indicators, Administrative

Symbols and Conventions

(i) Definition of NAIC Designation Categories

NAIC Designations are proprietary symbols that the NAIC SVO uses to denote a category or

band of credit risk. NAIC Designations are produced for statutory accounting, reporting, state

investment laws and other purposes identified in the NAIC Financial Regulation Standards and

Accreditation Program and or other NAIC developed regulatory guidance embodied in state

law.

NAIC Designations are adjusted in accordance with the notching procedures described in

subparagraph (iii) (A), (B) and (C) below, so that an NAIC Designation for a given security

reflects the position of that specific security in the issuer’s capital structure.

NAIC Designations may also be adjusted by notching to reflect the existence of other non-

payment risk in the specific security in accordance with the procedures described in

subparagraph (ii) and (iii) (C) below.

When applied to preferred stock, the valuation indicator P is placed in front of the NAIC

Designation to indicate that the SVO has classified the security as a perpetual preferred stock.

The valuation indicator RP is placed in front of the NAIC Designation to indicate that the SVO

has classified the security as a redeemable preferred stock for the purposes of valuation under

SAP.

NAIC 1 is assigned to obligations exhibiting the highest quality. Credit risk is at its lowest and

the issuer's credit profile is stable. This means that interest, principal or both will be paid in

accordance with the contractual agreement and that repayment of principal is well protected. An

NAIC 1 obligation should be eligible for the most favorable treatment provided under the NAIC

Financial Conditions Framework.

NAIC 2 is assigned to obligations of high quality. Credit risk is low but may increase in the

intermediate future and the issuer's credit profile is reasonably stable. This means that for the

present, the obligation's protective elements suggest a high likelihood that interest, principal or

both will be paid in accordance with the contractual agreement, but there are suggestions that an

adverse change in circumstances or economic, financial or business conditions will affect the

degree of protection and lead to a weakened capacity to pay. An NAIC 2 obligation should be

eligible for relatively favorable treatment under the NAIC Financial Conditions Framework.

NAIC 3 is assigned to obligations of medium quality. Credit risk is intermediate and the issuer's

credit profile has elements of instability. These obligations exhibit speculative elements. This

means that the likelihood that interest, principal or both will be paid in accordance with the

contractual agreement is reasonable for the present, but an exposure to an adverse change in

circumstances or economic, financial or business conditions would create an uncertainty about

Comment [KM1]: Deleted RP and P prefixes used for preferred stock are to be eliminated. 6/4/18

Attachment C


6/11/18


the issuer's capacity to make timely payments. An NAIC 3 obligation should be eligible for less

favorable treatment under the NAIC Financial Conditions Framework.

NAIC 4 is assigned to obligations of low quality. Credit risk is high and the issuer's credit

profile is volatile. These obligations are highly speculative, but currently the issuer has the

capacity to meet its obligations. This means that the likelihood that interest, principal or both

will be paid in accordance with the contractual agreement is low and that an adverse change in

circumstances or business, financial or economic conditions would accelerate credit risk,

leading to a significant impairment in the issuer's capacity to make timely payments. An NAIC

4 obligation should be accorded stringent treatment under the NAIC Financial Conditions

Framework.

NAIC 5 is assigned to obligations of the lowest credit quality, which are not in or near default.

Credit risk is at its highest and the issuer’s credit profile is highly volatile, but currently the

issuer has the capacity to meet its obligations. This means that the likelihood that interest,

principal or both will be paid in accordance with the contractual agreement is significantly

impaired given any adverse business, financial or economic conditions. An NAIC 5 Designation

suggests a very high probability of default. An NAIC 5 obligation should incur more stringent

treatment under the NAIC Financial Conditions Framework.

NAIC 6 is assigned to obligations that are in or near default. This means that payment of

interest, principal or both is not being made, or will not be made, in accordance with the

contractual agreement. An NAIC 6 obligation should incur the most severe treatment under the

NAIC Financial Conditions Framework.

(ii) NAIC Designation Categories

Upon the determination of an NAIC Designation, the SVO produces NAIC Designation

Categories, as described and defined in Part Two, Section 1 of this Manual below. .

…

NAIC

Designation +

NAIC

Designation

Modifier =

NAIC

Designation

Category

1 A 1.A

1 B 1.B

1 C 1.C

1 D 1.D

1 E 1.E

1 F 1.F

1 G 1.G

2 A 2.A

2 B 2.B

2 C 2.C

3 A 3.A

3 B 3.B

3 C 3.C

4 A 4.A

4 B 4.B

4 C 4.C

5 A 5.A

5 B 5.B

5 C 5.C

6 A 6.A

NR NR

Comment [KM2]: Deleted. References to the NR symbol as a designation were included by mistake 6/4/18

Attachment C


6/11/18


NAIC Designation Categories are a subset of NAIC Designations and are used by the VOS/TF

to link the NAIC risk-based-capital (RBC) framework adopted by the NAIC Capital Adequacy

(E) Task Force to the VOS/TF’s credit assessment process. The NAIC Capital Adequacy (E)

Task Force assigns RBC factors to each NAIC Designation Category as shown below.

NAIC

Designation

NAIC

Designation

Category

SVO

Administrative

Symbol

Proposed Life

RBC Factor

1 1.A GE 0.00%

1 1.A GSE 0.00%

1 1.A 0.31%28%

1 1.B 0.43%

1 1.C 0.6357%

1 1.D 0.729%

1 1.E 0.9686%

1 1.F 1.1306%

1 1.G 1.3024%

2 2.A 1.4942%

2 2.B 1.6869%

2 2.C 2.001%

3 3.A 3.5575%

3 3.B 4.3976%

3 3.C 5.626.16%

4 4.A 5.996.35%

4 4.B 7.868.54%

4 4.C 10.3111.82%

5 5.A 14.4517.31%

5 5.B 19.8523.22%

5 5.C 29.8230.00%

6 6.A 30.00%

Note: RBC factors are set by the NAIC Capital Adequacy (E) Task Force, not the VOS/TF. RBC

factors are shown above to illustrate the process under discussion. Please consult the NAIC Capital

Adequacy (E) Task Force and its guidance for an understanding on how RBC is applied.

…

Part Two Filing with the SVO

Section 1 - General Definitions Used In This Manual

Formatted Table

Comment [RC3]: Do we want to publish the RBC factors in the P&P Manual with an appropriate disclaimer – shown below.

Comment [CAT4]: American Academy of Actuaries proposal to the IRBCWG in their Ocotber 10, 2017 letter.

Comment [KM5]: 1.Table will be deleted. The final table with the approved RBC factors can be included in the future when they are finalized.

2. The two additional proposed identifiers for U.S. Government entities as a 1.US and U.S. government sponsored entities (GSEs) as a 1.GS was intended to facilitate reporting for RBC purposes by providing a consistent means to identify NAIC designations based upon these policy exceptions. The intent was not to introduce changes in differences in treatment. If that is the effect of this proposal we would delete these portions of the proposal. IRBCWG and Capital Adequacy can decide if it will be useful to have these additional administrative symbols for reporting purposes. 6/4/18

Formatted Table

Attachment C


6/11/18


…

NAIC Designation means any one of the gradations of credit quality and credit risk identified by the NAIC 1 through NAIC

6 symbols defined in Part One, Section 3(b)(i) of this Manual and may reflect notching pursuant to one or both of the

notching procedures discussed in Part One, Section 3 (b) (iii) of this Manual.

NAIC Designation Category means and refers to 20 more granular delineations of credit risk in the NAIC 1 through NAIC

6 credit risk scale used by the VOS/TF to relate credit risk in insurer owned securities to a risk based capital factor assigned

by the NAIC Capital Adequacy (E) Task Force. Each delineation of credit risk is represented by a letter (a Modifier) which

modifies the NAIC Designation grade to indicate a more granular measure of credit risk within the NAIC Designation grade.

The more granular delineations of credit risk are distributed as follows: 7 for the NAIC 1 Designation grade indicated by the

letters A through G; 3 delineations each for each of the NAIC Designation grades NAIC 2, NAIC 3, NAIC 4 and NAIC 5

indicated by the letters A, B and C and 1 delineation for NAIC Designation grade NAIC 6. indicated by the letter Aand 1

delineation for non-designated securities with an NAIC Designation grade of NAIC NR. The NAIC Designation Category

framework is shown in Part Three, Section 1 (e) of this Manual. All Modifiers roll up into the respective NAIC Designation

grade as they are a subset of them.

Part Three Credit Assessment

Section 1 - Corporate and Preferred Stock

(b) Procedure Applicable to Filing Exempt (FE) and to Private Letter (PL) Rating Securities

(iii) Direction and Procedure

The SVO shall produce NAIC Designations for FE securities by applying the following

procedure in conjunction with the List of Credit Rating Providers and the Equivalent of their

Credit Ratings to NAIC Designations, shown below.

A Bond or Preferred Stock that has been assigned an Eligible NAIC CRP Rating will

be assigned the equivalent NAIC Designation.

If two Eligible NAIC CRP Ratings have been assigned, then the lowest credit rating

will be used to assign the equivalent NAIC Designation.

In case of a Bond or Preferred Stock that has been assigned three or more Eligible

NAIC CRP Ratings, the Eligible NAIC CRP Ratings for the Bond or Preferred Stock

will be ordered according to their NAIC equivalents and the credit rating falling second

lowest will be used to determine the equivalent NAIC Designation, even if that rating

is equal to that of the first lowest. …

(vii) CRP Credit Rating Equivalents to NAIC Designations and to NAIC Designation Categories

Please note that the existence of a rating does not eliminate the requirement to file on SAR on

any insurer owned security not currently listed in the VOS manual unless exempted from filing

as detailed in Part Three, Section 1 (b) of this Manual.

Comment [KM6]: Deleted text referring to NR. 6/4/18

Attachment C


6/11/18


Comment [KM7]: Translations to NAIC designations added: Fitch • CCC+ mapped to 5.A • CCC mapped to 5.B • CCC- mapped to 5.C • CC, C, DDD, DD, D mapped to 6 DBRS • CCC (high) mapped to 5.A • CCC mapped to 5.B • CCC (low) mapped to 5.C • CC (high), CC, CC (low), C (high) C, C (low), D mapped to 6 Revised 6/4/18

Comment [KM8]: Final table with approved RBC factors can be included in the future when they are finalized. 6/4/18

Comment [KM9]: Translations to NAIC designations added: Fitch • CCC+ mapped to 5.A • CCC mapped to 5.B • CCC- mapped to 5.C • CC, C, DDD, DD, D mapped to 6 DBRS • CCC (high) mapped to 5.A • CCC mapped to 5.B • CCC (low) mapped to 5.C • CC (high), CC, CC (low), C (high) C, C (low), D mapped to 6 Revised 6/4/18

Comment [KM10]: Morningstar’s ratings have been filled in. 6/15/18 and 8/30/18

Comment [KM11]: Final table with approved RBC factors can be included in the future when they are finalized. 6/4/18

Attachment C


6/11/18


(A) Moody’s Investor’s Service

Corporate, Government Counterparty and

Municipal Ratings NAIC

Aaa; Aa 1, 2, 3; A 1, 2, 3 1

Baa 1, 2, 3 2

Ba 1, 2, 3 3

B 1, 2, 3 4

Caa, 1, 2, 3 5

Ca, C 6

Commercial Paper and

Short Term Counterparty Ratings NAIC

P 1 1

P 2 2

P 3 3

N P (Not prime) 6

Preferred Stock NAIC

Aaa; Aa 1, 2, 3; A 1, 2, 3 1

Baa 1, 2, 3 2

Ba 1, 2, 3 3

B 1, 2, 3 4

Caa 5

Ca, C 6

NAIC Designation

NAIC Designation

Modifier

NAIC Designation

Category

Moody’s CRP

Credit Rating

Mapping

1 A 1.A Aaa

1 B 1.B Aa1

1 C 1.C Aa2

1 D 1.D Aa3

1 E 1.E A1

1 F 1.F A2

1 G 1.G A3

2 A 2.A Baa1

2 B 2.B Baa2

2 C 2.C Baa3

3 A 3.A Ba1

3 B 3.B Ba2

3 C 3.C Ba3

4 A 4.A B1

4 B 4.B B2

4 C 4.C B3

5 A 5.A Caa1

5 B 5.B Caa2

5 C 5.C Caa3

6 A 6.A Ca-C, D

(B) Standard and Poor’s

Corporate Counterparty and Municipal Ratings --

Public Bonds NAIC

Attachment C


6/11/18


AAA, AA+, AA, AA-, A+, A, A- 1

BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC+, CCC, CCC- 5

CC, C, D 6

Commercial Paper (Standard & Poor’s continued) NAIC

A, A 1 1

A 2 2

A 3 2

B 4

C 5

D 6



BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC 5

CC, C, D 6

NAIC Designation

NAIC Designation

Modifier

NAIC Designation

Category

Standard and

Poor’s CRP

Credit Rating

Mapping

1 A 1.A AAA

1 B 1.B AA+

1 C 1.C AA

1 D 1.D AA-

1 E 1.E A+

1 F 1.F A

1 G 1.G A-

2 A 2.A BBB+

2 B 2.B BBB

2 C 2.C BBB-

3 A 3.A BB+

3 B 3.B BB

3 C 3.C BB-

4 A 4.A B+

4 B 4.B B

4 C 4.C B-

5 A 5.A CCC+

5 B 5.B CCC

5 C 5.C CCC-

6 A 6.A CC,C,D

(C) Fitch Ratings

Fixed Income and Counterparty Ratings NAIC

AAApre 1*


BBB+, BBB, BBB- 2

BB+, BB, BB- 3

Attachment C


6/11/18


B+, B, B- 4

CCC, 5

CC, C, DDD, DD, D 6 * This rating is assigned to pre-refunded municipal debt.

Commercial Paper NAIC

F 1+, F 1 1

F 2 2

F 3 2

B 4

C 5

D 6



BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC 5

CC, C 6

NAIC Designation

NAIC Designation

Modifier

NAIC Designation

Category

Fitch CRP Credit

Rating Mapping

1 A 1.A AAApre, AAA

1 B 1.B AA+

1 C 1.C AA

1 D 1.D AA-

1 E 1.E A+

1 F 1.F A

1 G 1.G A-

2 A 2.A BBB+

2 B 2.B BBB

2 C 2.C BBB-

3 A 3.A BB+

3 B 3.B BB

3 C 3.C BB-

4 A 4.A B+

4 B 4.B B

4 C 4.C B-

5 A 5.A CCC

5 B 5.B CC

5 C 5.C C

6 A 6.A DDD, DD, D

(D) Dominion Bond Rating Service

Bond and Long Term Debt NAIC

AAA, AA (high), AA, AA (low), A (high), A, A (low) 1

BBB (high), BBB, BBB (low) 2

BB (high), BB, BB (low) 3

B (high), B, B (low) 4

CCC (high 5

Attachment C


6/11/18


CC, C (low), D 6


Pfd-1 (high), Pfd-1, Pfd 1 (low) 1

Pfd-2 (high), Pfd-2, Pfd-2 (low) 2



Pfd-5 (high), 5

Pfd-5, Pfd-5 (low), D 6

Commercial Paper and Short Term Debt NAIC

R 1 (high), R-1 (middle), R-1 (low) 1

R 2 (high), R-2 (middle), R-2 (low) 2

R-3 3

R-4 5

R-5, D 6

NAIC Designation

NAIC Designation

Modifier

NAIC Designation

Category

Dominion CRP

Credit Rating

Mapping

1

1

1

1

1

1

1

2

2

2

3

3

3

4

4

4

5

5

5

6

(E) A.M. Best Company

Bond, Long Term Debt and Preferred NAIC

aaa, aa+, aa, aa-, a+, a, a- 1

bbb+, bbb, bbb- 2

bb+, bb, bb- 3

b+, b, b- 4

ccc+, ccc, ccc- 5

cc, c, d 6

Commercial Paper and Short Term Debt NAIC

AMB-1+, AMB-1 1

AMB-2 2

AMB-3 3

AMB –4 6

Attachment C


6/11/18


NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

A.M. Best CRP

Credit Rating

Mapping

1

1

1

1

1

1

1

2

2

2

3

3

3

4

4

4

5

5

5

6

(F) Morningstar Credit Ratings, LLC

Fixed Income and Counterparty Ratings NAIC

AAA, AA, A 1

BBB 2

BB 3

B 4

CCC+, CCC, CCC- 5

CC, C* §, D 6

* This rating is not applicable to structured finance securities. § Morningstar defines CC, C as "likely to default" which we here

equate to the NAIC 6 definitional concept of a security "in or near

default." Morningstar's D, defined as "in default" is also equated to an

NAIC 6.

NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Morningstar

CRP Credit

Rating Mapping

1

1

1

1

1

1

1

2

2

2

3

Attachment C


6/11/18


NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Morningstar

CRP Credit

Rating Mapping

3

3

4

4

4

5

5

5

6

(G) Kroll Bond Rating Agency

Long-Term Corporate, Counterparty and

Municipal Ratings NAIC


BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC+, CCC, CCC- 5

CC, C, D 6

Short-Term and Commercial Paper Ratings NAIC

K1+, K1 1

K2 2

K3 3

B 4

C 5

D 6

Preferred Stock Ratings NAIC


BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC+, CCC, CCC- 5

CC, C, D 6

NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Kroll CRP

Credit Rating

Mapping

1

1

1

1

1

1

1

2

2

2

3

3

3

Attachment C


6/11/18


NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Kroll CRP

Credit Rating

Mapping

4

4

4

5

5

5

6

(H) Egan Jones Rating Company

Corporate Ratings NAIC


BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC+, CCC, CCC- 5

CC, C, D 6

Commercial Paper NAIC

A, A1, A1+ 1

A2 2

A3 2

B 4

C 5

D 6



BBB+, BBB, BBB- 2

BB+, BB, BB- 3

B+, B, B- 4

CCC 5

CC, C, D 6

NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Egan Jones CRP

Credit Rating

Mapping

1

1

1

1

1

1

1

2

2

2

3

3

3

4

4

Attachment C


6/11/18


NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

Egan Jones CRP

Credit Rating

Mapping

4

5

5

5

6

(I) HR Ratings de Mexico, S.A. de C.V.

Government Counterparty and Municipal Ratings NAIC

HR AAA (G), HR AA+ (G), HR AA (G), HR AA- (G),

HR A+ (G), HR A (G), HR A- (G)

1

HR BBB+ (G), HR BBB (G), HR BBB- (G) 2

HR BB+ (G), HR BB (G), HR BB- (G) 3

HR B+ (G), HR B (G), HR B- (G) 4

HR C+ (G), HR C (G), HR C- (G) 5

HR D (G) 6

NAIC

Designation

NAIC

Designation

Modifier

NAIC

Designation

Category

HR Ratings de

Mexico CRP

Credit Rating

Mapping

1

1

1

1

1

1

1

2

2

2

3

3

3

4

4

4

5

5

5

6

….

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showing the amendment adopted on june 11, 2018 by the …...the task force considered holding a...

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