1

CREDIT RATING REPORT

Gruh Finance Limited

September 2016

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Instruments & ratings

Non-Convertible Debenture aggregating Rs.13.5

Billion

CRISIL AAA/Stable (Upgraded from 'CRISIL

AA+/Positive')

Rs.1.5 Billion Subordinated Debt Issue CRISIL AAA/Stable (Upgraded from 'CRISIL

AA+/Positive')

Fixed Deposit Programme FAAA/Stable (Reaffirmed)

Rs.44.5 Billion Short-Term Debt Programme CRISIL A1+ (Reaffirmed)

Analytical contacts

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available on www.crisil.com/complexity-levels. Investors are advised to refer to the CRISIL Complexity Levels for

instruments that they propose to invest in. Investors can also call the Customer Service Helpdesk with queries on

specific instrument

Krishnan Sitaraman Senior Director - CRISIL Ratings Phone:+91 22 3342 8070 krishnan.sitaraman@crisil.com

Suresh Krishnamurthy Director - CRISIL Ratings Phone:+91 22 3342 1952 suresh.krishnamurthy@crisil.com

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Rating History Date Long-term Fixed deposit Short-term Rating watch/ Outlook

September 08, 2016 CRISIL AAA FAAA CRISIL A1+ Stable

May 03, 2016 CRISIL AA+ FAAA CRISIL A1+ Positive

November 18, 2013 CRISIL AA+ FAAA CRISIL A1+ Stable

Analytical approach and adjustments

Portfolio performance/networth/

gearing/parent or group support Analytical treatment

Return on assets (RoA) CRISIL has used RoA to measure profitability in the absence of a securitised portfolio.

Adjusted networth Networth is adjusted for intangible assets and deferred tax assets

Weak Assets CRISIL calculates weak assets for housing finance companies (HFCs) by taking the current

year’s gross non-performing assets (NPAs) as a percentage of gross advances two years ago

Support from parent Gruh Finance’s strategic importance to, and significant support expected from, the parent

Housing Development Finance Corporation Ltd (HDFC; rated ‘CRISIL

AAA/FAAA/Stable/CRISIL A1+’) is factored into the ratings.

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Rating drivers

CRISIL has revised its ratings on the long-term debt instruments of Gruh Finance Ltd (Gruh) to CRISIL

AAA/Stable, from 'CRISIL AA+/Positive'. The rating on the company's fixed deposit programme and short-term

debt programme have been reaffirmed at 'FAAA/Stable/CRISIL A1+'. The rating upgrade is driven by the

demonstrated ability of Gruh to maintain healthy asset quality through economic cycles along with maintaining

steady growth in its loan book and strong profitability. This is despite the inherent challenges in lending to

relatively riskier low-income group customer segments. Gruh has been able to develop strong risk

management systems and processes given the business understanding emanating from a three decade long

presence in this segment. The ratings continue to reflect the expectation of continued strong support from its

majority owner, HDFC. Gruh is also expected to benefit arising from strong growth potential in the affordable

housing segment as the Government of India is offering incentives to promote faster development of the

affordable housing segment. Gruh is expected to maintain comfortable profitability over the medium term

driven by relatively high net interest margins and continued low credit costs. These rating strengths are

partially offset by the company’s modest asset liability management (ALM) profile given its high dependence

on short-term funds, and geographical concentration.

Supporting:

Expectation of continued strong support from the company’s majority owner, HDFC

Healthy asset quality

Comfortable earning profile

Constraining:

Modest asset-liability management (ALM) profile given its high dependence on short-term funds

Geographical concentration in operations

Outlook: Stable

CRISIL believes HDFC will retain its majority shareholding in Gruh, and continue to extend strategic,

management, and financial support to the company, over the medium term. Moreover, the company will

maintain healthy asset quality and a comfortable earnings profile over this period.

Downside Scenario: The outlook may be revised to negative if there is

Diminution in support from HDFC, or weakening, in CRISIL's view, of HDFC's credit risk profile.

Significant and sustained weakening in Gruh's asset quality or earnings profile

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Classification: EXTERNAL

Recent developments and performance update

As on June 30, 2016, loan book increased to Rs 115.4 billion (Rs 111.1 billion as on March 31, 2016 and Rs

93.3 billion as on June 30, 2015) , representing a year-on-year growth of 24%, driven by high growth in

the self-employed individuals segment.

Gross NPA and Net NPA remained below industry average at 0.56% and 0.27% as on June 30, 2016 (0.32%

and 0.09% as on March 31, 2016). Weak assets (two-year lagged gross NPAs), was at 0.87% as on June 30,

2016 (0.5% as on March 31, 2016).

Resource profile is diversified with National Housing Board (NHB) financing and bank loans forming 39%

and 38%, respectively of the borrowings as on March 31, 2016. Fixed deposits and non-convertible

debentures (NCDs) form remaining 14% and 9%, respectively. Average cost of borrowing declined to 8.75%

for FY16 from 9.24% in FY15.

Tier-I and overall capital adequacy ratios were 16.1% and 17.8%, respectively, as on March 31, 2016 (13.9%

and 15.4%, respectively, as on March 31, 2015). Networth was Rs 8.35 billion as on March 31, 2016 (Rs 7.1

billion as on March 31, 2015). However, gearing, at 12.3 times as on March 31, 2016 (11.5 times as on

March 31, 2015), remained higher than the industry average. Further, as on June 30, 2016, the gearing

remained high at 12.1 times.

Profitability levels are higher than industry average as the RoA was 2.4% for FY16, which is similar to that

of FY15. Profitability is driven by relatively high interest yields (12.4% in FY16) and efficient treasury

management resulting in healthy interest spreads vis-à-vis its peers. Return on networth remains healthy at

32.1% in FY16 compared to 31.0% in FY15. For the first quarter ended June 30, 2016, the RoA of the

company was 2.1% (annualised) which is at a similar level to that of previous fiscal.

About the company

Gruh (formerly, Gujarat Rural Housing Corporation Ltd) was set up in 1986 by HDFC and the Aga Khan Fund

for Economic Development, with the objective of providing an institutional structure to rural housing finance.

Gruh primarily extends housing loans to individuals in rural and semi-urban areas to relatively low-income

group market segment for multiple purposes, ranging from house construction to renovation. The company

has a distinct target market segment, which complements HDFC’s market.

Shareholding pattern as on June 30, 2016

Shareholder particulars %

1 Promoter and promoter group 58.59

HDFC 58.59

2 Public 41.11

Mutual Funds 4.26

Foreign Portfolio investors 13.59

Others 23.26

Total 100.0

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Key credit factors

Industry risk profile

Housing Financing Companies (HFCs) - Performance to hold steady

Growth in the HFC industry—with outstanding advances estimated at Rs 6.8 trillion as on March 31, 2016—

reduced marginally to around 20.3% in fiscal 2016, from 21.2% the previous fiscal. Growth may slow down

even further, to around 19.0% in fiscal 2017 (refer to Chart 1). The slowdown is primarily on account of

intensified competition in individual home loans, and subdued growth in the developer finance segment.

Growth in loans against property may remain healthy, though lower than in the past. Growth in individual

home loans will be driven primarily by Tier-II and -III cities, with affordability in the metros continuing to be

low.

Competition in individual home loans is expected to remain intense. On account of lower demand from the

corporate segment, and lower risk weights and strong asset quality in home loans, banks have been increasing

focus on the housing finance segment. As a result, for the first time in several years, growth in the banks’

home loans outpaced those of HFCs in fiscal 2016; the trend should continue in fiscal 2017 as well (refer to

Chart 2). Among HFCs, the mid-sized HFCs1 continue to grow at twice the pace of the large HFCs2.

Chart 1: Overall advances growth slows down for HFCs Chart 2: Banks outpace HFCs on growth in home loans

Asset quality remains comfortable for HFCs, with gross NPAs estimated at 0.7% as on March 2016 and only a

marginal increase expected by March 2017 (refer to Chart 3). Asset quality in individual home loans should

remain steady, as also reflected in the performance of CRISIL-rated mortgage-backed security (MBS) pools.

However, with seasoning in the portfolios of rapidly-growing HFCs, many of which are focused on the self-

employed customers, there could be an increase in delinquencies in that segment. Asset quality in the non-

individual segment will also be closely monitored, given the pressure on real estate developers. Though the

performance of the large and mid-sized HFCs continues to be similar on gross NPAs, there is still a marked

1 Advances between 40-400 billion as on March 31, 2016

2 Advances above 400 billion as on March 31, 2016

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Classification: EXTERNAL

difference in the two-year lagged GNPAs. This is primarily because the mid-sized HFCs have grown

considerably in recent years, and a large proportion of their loan book remains unseasoned.

Chart 3: Asset quality to remain comfortable for HFCs

Profitability may remain adequate over the medium term, with the HFCs’ return on assets (RoA) expected at

2.0-2.1% (refer to Chart 4). Despite improvement in the interest rate scenario, RoA may continue to be range-

bound on account of the competitive dynamics in the home loan market. Spreads in the individual loan

segment may witness some pressure, but this should be partially offset by other segments. Until recently, the

mid-sized HFCs did maintain profitability at levels comparable with those of the large HFCs, with higher net

interest margins (NIMs) offsetting higher operating expenditure and credit costs. However, with competitive

pressures intensifying, and yield differential between large and mid-sized HFCs reducing, the profitability of the

mid-sized players has begun to feel the impact and is now around 30 basis points lower than that of the large

HFCs.

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Chart 4: Profitability to remain adequate

One of the areas than has seen significant action, both in terms of new entrants as well as policy push, is

affordable housing. A major chunk of the demand for housing over the next few years may be in this segment,

where the financing potential is sizeable. With the Government of India offering incentives such as credit-

linked subsidy to customers, and schemes for builders under ‘Affordable Housing in Partnership’, under the

Pradhan Mantri Awas Yojana, several HFCs, whether part of a larger financial services group or funded by

private equity, have entered the segment in recent years. However, the growth experience has been different

and has been dependent to a large extent on the capital available and the gearing philosophy, which varies

significantly among these entities. Furthermore, asset quality remains to be tested, given the lack of seasoning

in most of these entities. Operating costs and credit costs are also high in this segment; therefore, the key

differentiators that can determine long-term sustainability and profitability will be the ability to attract capital

and borrow at competitive rates.

Parent support

Strong support from parent, HDFC

HDFC is expected to continue to provide strategic, management, and financial support to GRUH. CRISIL

believes that HDFC will likely retain its majority ownership in the company over the medium term. However,

the extent of HDFC’s ownership in, and support to, the company remains a rating sensitivity factor.

HDFC owns 58.6% of GRUH’s equity shares as on June 30, 2016. GRUH derives strong management support

from HDFC in formulation of guidelines and policies. HDFC’s vice-chairman and chief executive officer, and

managing director are GRUH’s chairman and non-executive director, respectively. GRUH’s managing director is

a former HDFC employee.

In the past, HDFC has also invested in GRUH’s subordinated debt programme and has bought GRUH’s

securitised portfolio. GRUH’s association with HDFC enables bank funding at competitive rates. Additionally,

9

Classification: EXTERNAL

HDFC extends support to GRUH, as its operating policy, sanctioning norms, and loan schemes are formulated

with inputs from HDFC.

GRUH is focused on a niche segment—primarily the low-income groups in rural and semi-urban areas—as

distinct from HDFC’s target segment; GRUH and HDFC are, therefore, not direct competitors, despite operating

in the same industry. GRUH also cross-sells HDFC products, such as insurance; the company is a referral agent

for HDFC Standard Life Insurance Company Ltd. However, the quantum of agency business remains small. The

extent of HDFC’s ownership in, and support to, Gruh will be a rating sensitivity factor.

Business risk profile

Higher-than-industry average loan growth, to capitalize on strong growth place in affordable housing

Chart 5: Trend in Disbursements Chart 6: Trend in portfolio outstanding

Gruh has maintained a higher-than-industry-average loan growth over the past several years. Its loan book

increased to Rs 111.1 billion as on March 31, 2016, registering a compound annual growth rate (CAGR) of 28%

against industry average of around 20% between 2011-12 and 2015-16. Loan disbursement also grew at a

strong CAGR of 27% over the same period.

Gruh has more than three decades of experience in the affordable housing segment and is therefore expected

to benefit from strong growth potential in the affordable housing segment. A major chunk of the demand for

housing over the next few years may be in this segment, where the financing potential is sizeable. Government

of India is also offering incentives such as credit-linked subsidy to customers, and schemes for builders under

‘Affordable Housing in Partnership’, under the Pradhan Mantri Awas Yojana. Further, state Governments such

as Maharashtra, Gujarat, Madhya Pradesh and Rajasthan are more active than other states in promoting the

affordable housing segment. Gruh has created a strong competitive position in affordable housing finance

segment. Its assets under management have grown at a compound annual growth rate of around 29% over

the past five years. The company has requisite expertise, reach and risk management systems to cater to this

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Salaried Construction finance

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segment which will translate to a strong growth potential for the company in this segment. CRISIL believes

Gruh, being a leading player, will benefit from the expected growth potential in the affordable housing finance

segment and maintain healthy growth over the medium term.

However, the company continues to be a relatively small player in the housing finance market which is

primarily dominated by banks and few large HFCs. Gruh faces stiff competition from these banks and other

housing companies. Gruh operates primarily in the rural and semi-urban areas of Gujarat and Maharashtra;

these two states accounted for 70% of outstanding loans as on March 31, 2016. Therefore, the company is

exposed to risks related to geographical concentration. However, operations have been expanded across other

states including Rajasthan, Madhya Pradesh, Tamil Nadu, Karnataka, Chhattisgarh, Uttar Pradesh, Jharkhand

and Bihar to support growth and diversification. Hence, risks related to geographic concentration are likely to

decline gradually over the medium term.

Healthy asset quality supported by its strong risk management systems

and processes

Chart 7: Trend in NPAs and weak assets

Gruh’s has demonstrated its ability to maintain healthy asset quality over the business cycles as the gross non-

performing assets (NPAs) have remained lower than the industry average, over the past few years. Its gross

NPAs were 0.32% as on March 31, 2016, as against the industry average of 0.7%. Additionally, weak assets

(two-year lagged gross NPAs), at 0.51% as on March 31, 2016, remains significantly lower than the industry

average of around 1.0%.

Asset quality has remained healthy, despite above-industry average growth in the loan portfolio over the past

five years. Further, the company has high exposure to relatively riskier self-employed segment (comprising

0.52

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Mar-12 Mar-13 Mar-14 Mar-15 Mar-16

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Gross NPA 2 year Lagged Gross NPA Net NPA

11

Classification: EXTERNAL

professionals, and customers with formal business income, and assessed income); at around 41% of the

advances as on March 31, 2016. Asset quality is supported by stringent credit appraisal, monitoring systems,

and processes, which helps the company to mitigate inherent challenges arising from lending to riskier low-

income customer segments. Furthermore, conservative lending policies have also helped Gruh minimise risks in

the builder loan segment; as there has been no delinquency in its portfolio for the past five years, though the

segment has always been a small proportion of its portfolio (3.9% of the portfolio as on March 31, 2016).

Gruh has benefitted from its linkages with the parent, and has put in place strong risk management systems as

reflected in the rigorous strong credit underwriting standards and efficient credit monitoring, and recovery

mechanisms. It has conservative loan eligibility norms. Currently, around 95% of the outstanding loan portfolio

has been sanctioned to individuals, which, therefore, reduces risks related to customer concentration (due to

low average ticket-size loans). Large exposures (above Rs 50 million) are primarily sanctioned to builders with

an established track record of more than five years.

CRISIL believes Gruh’s strong risk management systems, prudent underwriting norms, and collection

mechanism will enable it to maintain healthy asset quality over the medium term.

Diversified resource profile and competitive borrowing costs

Chart 8: Borrowing mix and cost of borrowing

Resource base is stable and adequately diversified. The company has established relations with over 25 banks,

and access to short-term funding from mutual funds and insurance companies. NHB financing, bank loans and

NCDs form 39% 38%, and 9%, of the borrowings as on March 31, 2016, respectively. Gruh also focuses on

raising retail deposits (around 14% as on March 31, 2016), which provides stability to its resource profile. It

raises fixed deposits with renewal rate of more than 50%. Further, Gruh regularly accesses the short-term debt

market, to take opportunistic advantage between short-term and long-term interest rates. In addition, the

5 11 2 8 9

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9.9%9.3% 9.6% 9.2% 8.8%

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20%

40%

60%

80%

100%

2011-12 2012-13 2013-14 2014-15 2015-16Bonds and Debentures BanksFixed deposits CPsNHB Cost of borrowing (yearly average- RHS)

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company also has an option of securitisation with HDFC, which further supports its resource profile. Average

cost of borrowing declined to 8.8% for FY16 from 9.2% in FY15 and remains lower than industry average.

Financial Risk Profile:

Adequate capitalisation

Chart 9: Trend in Net Worth and Capital Adequacy

Capitalisation is adequate in relation to current business and growth plans, underpinned by healthy accrual to

net worth and flexibility to raise additional capital, if required. The company had an adequate tangible net

worth of Rs 8.35 billion as on March 31, 2016 (Rs.7.1 billion as on March 31, 2015). Tier I and overall capital

adequacy ratios increased to 16.1% and 17.8%, respectively, as on March 31, 2016 (13.9% and 15.4%,

respectively, as on March 31, 2015) on account of reduction in risk weights for the housing loan.. Capitalisation

is supported by healthy accretion to networth (return on equity exceeding 30% over the past three years),

flexibility to raise additional capital if required, and robust asset quality. A significantly high provision cover for

NPAs provides strong cushion against asset-side risks. However, Gruh has a higher-than-industry average

gearing of 12.3 times as on March 31, 2016 (11.5 times as on March 31, 2015) and remains a key monitorable.

CRISIL believes that Gruh will maintain adequate capitalisation, supported by healthy accruals to net worth,

flexibility to raise capital and strong net worth coverage for asset-side risks.

3.9 4.9 6.1 7.1 8.4

14.0%14.6%

16.4%

15.4%

17.8%

12%

13%

14%

15%

16%

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2012 2013 2014 2015 2016

Rs.

Bil

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Networth (LHS) CAR (RHS)

As on March 31,

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Classification: EXTERNAL

Comfortable earning profile, due to high spreads and low credit costs

Chart 10: Trend in PAT and ROA

Earnings profile remains comfortable, marked by higher-than-industry average return on assets (RoA). This is

primarily driven by higher interest yields and lower than industry average borrowing costs, supported by

efficient treasury management practices. Gruh’s RoA has remained above or close to 2% on a consistent basis,

which is higher than that of some large housing finance companies. RoA at 2.4% in 2015-16 remained higher

than that of peers (industry average RoA of 2.1% in 2015-16). The company’s RoA, however, has declined from

high levels three years back due to pressure on interest yields. Increased competition, primarily from banks, is

lowering interest yields in the industry. GRUH’s net profitability margin (NPM) in fiscal 2016 remains higher

than industry average at 2.86%, despite declining from 3.0% in fiscal 2015. Decline in yields has been partially

compensated by lower interest costs in fiscal 2016, resulting in marginal decline in spreads.

Table 1: Trend in Net Profitability Margin

(In per cent)

For the year ended 2015-16 2014-15 2013-14 2012-13

Yield on Average Funds Deployed 12.04 12.65 12.84 12.63

Borrowing Cost 8.75 9.24 9.67 9.23

Spread 3.29 3.41 3.16 3.40

Operating Expenses/Average Funds Deployed 0.83 0.79 0.88 0.95

Core fee income/Average Funds Deployed 0.40 0.41 0.53 0.46

Net Profitability Margin 2.86 3.02 2.83 2.91

Strong focus on the affordable housing segment helps generate above-average yields. Furthermore, Gruh

raises significant short-term debt through commercial paper that carries relatively low interest rates and help

reduce overall interest cost compared to the industry average.

1.2 1.5 1.8 2.0 2.4

3.0%2.8%

2.7%2.4% 2.4%

0.0%

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1.0%

1.5%

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2.5

3

2012 2013 2014 2015 2016

Rs.

Bil

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n

As on March 31,

PAT (LHS) ROA (RHS)

14

Gruh also has robust asset quality, thus supporting its profitability. Its credit costs are expected to remain low

(0.22% of average assets in FY16) over the medium term. Gruh’s policy of maintaining significantly high

provision to cover NPAs also reduces the impact of adverse asset quality movements on its future earnings.

Gruh’s operating expenses also remain low and have declined from earlier high levels. Its operating expenses

at 0.87% of the average assets in FY16, declined from the level of 1.09% in FY11.

CRISIL believes that while the company’s profitability may moderate driven by intense competition from banks

and other HFCs, profitability is expected to remain better than that of its peers over the medium term

supported by healthy interest spreads and low credit costs.

Modest ALM profile

Gruh resorts to short-term debt to benefit from relatively lower interest rates for short-term loans as

compared to rates for long-term loans. As a result, the company runs negative cumulative mismatches in

short-term buckets of up to one year. While the company has positive cumulative mismatches in the upto one

year maturity bucket as on March 31, 2016, this may not sustain at all points in time.

However, Gruh’s liquidity through unutilised National Housing Board (NHB) limits and bank lines, and fixed

deposits with banks of Rs 12.2 billion as on March 31, 2016, adequately covered the negative cumulative

mismatches in the maturity bucket of up to one year. Further, the company has efficiently managed ALM

mismatches thus far, across interest rate cycles, and during stretched liquidity situations in the market,

reflecting its good treasury management practices and good relationships with its bankers. Ability to manage

asset-liability mismatches and liquidity in tight liquidity conditions remains a key monitorable.

Base case assumptions for 2016-17

AUM growth 23%-25%

Gearing 12 to 13 times

RoA 2.3%-2.5%

15

Classification: EXTERNAL

Management Assessment:

Organisation structure

Name Designation

Mr. Sudhin Choksey Managing Director

Mr. Kamlesh Shah Executive Director

Mr. Hitesh Agarwal Chief Financial Officer

Mr. Amit Chokshi General Manager -Project Finance & Legal

Mr. Suresh Iyer General Manager -Operations

Mr. Marcus Lobo Company Secretary

Mr. Jayesh Gangwani Chief Manager

Mr. Venu G Menon Head Resources

Experienced management with strong risk management practices

Gruh has a professional and experienced senior management team having more than two decades of

experience in the housing finance industry. Despite the company’s higher-than-industry average growth rate,

the management has put in place strong risk management practices. Further, the management has a strong

focus on maintaining healthy profitability level. This is also reflected in the company’s lower-than-industry

average gross NPA levels and higher the industry average RoA levels.

16

Financial Summary

As on / for the period ended March 31

2016 2015 2014 2013 2012

Equity Capital Rs Billion 0.7 0.7 0.4 0.4 0.4

Net Worth (Reported) Rs Billion 8.3 7.1 6.1 4.9 3.9

Borrowings Rs Billion 102.1 82.2 64.5 49.1 38.3

Disbursement Rs Billion 38.6 31.2 25.8 21.7 14.9

Housing Loans Outstanding Rs Billion 111.1 89.1 70.0 54.4 40.8

Total Assets Rs Billion 114.4 91.8 71.5 56.0 43.4

Interest Income Rs Billion 12.3 10.2 8.1 6.2 4.9

Interest Expense Rs Billion 8.1 6.8 5.4 4.0 3.1

Total Income (Net of Interest Expenses) Rs Billion 4.7 3.8 3.0 2.5 2.0

Operating Expense Rs Billion 1.1 0.8 0.6 0.5 0.4

Reported PAT Rs Billion 2.4 2.0 1.8 1.5 1.2

Ratio

PAT/Average Total Assets % 2.4 2.4 2.7 2.8 3.0

PAT/Average Reported Net Worth % 31.5 30.9 32.2 33.3 34.2

Tier-I Capital Adequacy Ratio % 16.1 13.9 14.7 12.9 13.3

Overall Capital Adequacy Ratio % 17.8 15.4 16.4 14.6 14.0

Total Debt/Reported Net Worth Times 12.2 11.5 10.3 10.0 9.9

Gross NPA % 0.3 0.3 0.3 0.3 0.5

Brief Financials for the Quarter ended June 30,

Particulars 2016 2015

Loan Outstanding Rs Billion 115.4 93.3

Disbursements Rs Billion 9.4 7.7

Interest Income Rs Billion 3.5 3.0

Interest expense Rs Billion 2.2 1.9

Total Income (Net of Interest) Rs Billion 1.3 1.1

Operating Expense (Including Depreciation) Rs Billion 0.2 0.2

Provision for Contingencies and Write-offs Rs Billion 0.1 0.1

Reported PAT Rs Billion 0.6 0.5

Ratios

PAT/Average Total Assets % 2.1 2.1

Gross NPA % 0.56 0.52

Total Debt/Net worth Times 12.1 11.3

Overall CAR % 16.7 15.5

17

Classification: EXTERNAL

Criteria Details

Links to related criteria

Rating Criteria for Finance Companies

Criteria for Notching up Stand Alone Ratings of Companies based on Parent Support

Criteria for rating Short-Term Debt (including Commercial Paper)

18

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