In consideration of Malaysia’s current structured finance market size and stage of development, MARC practices rotation of analysts on an individual basis rather than changing an entire team to determine initial ratings and subsequent monitoring on a rated subject. It has always been MARC’s top priority to ensure that analysts are rotated as much as our capacity and resources permit to avoid potential conflict of interest.

MARC believes that base cashflow models and assumptions for a particular structured finance transaction should be provided by issuers or arrangers. With such information, investors and subscribers would be able to construct their own cashflow models with first hand information. MARC is currently not prepared to extend existing proprietary models due to liability as well as intellectual property rights considerations. MARC, however, does provide information on the sensitivity of our modeled cashflow to changes in key variables. The principles on confidentiality granted to the whistleblower will also apply equally to the employee under investigation. MARC has an independent investigation process to investigate all whistleblowing reports based on investigation protocol which accords with the principles of fairness, independence and propriety. Where the improper conduct involves a suspected criminal offence, MARC will report the matter to the relevant authority for their further action and unless compelled by law, will strictly safeguard the identity of the whistleblower in accordance with the Whistleblowers Protection Act 2010 (Act 711).

The current IOSCO Code of Conduct requires credit rating agencies to differentiate the rating of structured finance products from traditional corporate bond ratings, preferably via different rating symbols, and to disclose how such differentiation functions. MARC uses the same rating scale and symbols for structured finance products as well as traditional corporate bonds.