Moody’s Investors Service has decided to out those issuers who decline to participate in its rating process.

The agency said that it made the decision to designate ‘non-participating’ issuers after having requested public comment on the proposal in August, and having received uniformly positive comments from market participants.

Moody’s stated that it will designate any published ratings where the issuer: has indicated to Moody’s its decision not to participate in the rating process, and has not participated in the process during the previous 12 months. Moody’s said that the 12-month period is relevant because ratings continue to be informed by past communications for some period of time after an issuer suspends participation.

Moody’s added that, if there is disagreement concerning an issuer’s participation or non-participation, the rating agency will generally defer to the issuer’s perspective in determining whether to designate.

The rating agency added that this policy expands Moody’s existing practice where it designates in the initial ratings press release any new rating assignment that is both unsolicited by the issuer and where the issuer has declined Moody’s invitation to participate in the analytic process.

The proposal came in response to market commentary that such information could be useful to the users of ratings. “Most issuers agree that the ratings process benefits from issuer participation,” said Christopher Mahoney, chairman of Moody’s Credit Policy Committee. “However, some choose not to participate for various reasons. Following positive feedback from market participants on the proposal, we will now publicly identify issuers that do not participate in the credit rating process.” Moody’s said that all issuers are provided the opportunity to participate in the rating process.

Moody’s said that discussions with market participants led it to conclude that some market participants believe that the absence of issuer meetings and other forms of communication could imply a different level of understanding of the issuer’s creditworthiness. “Because all published ratings meet Moody’s standards for accuracy and quality, and are conducted using the same rigorous approach irrespective of the issuer’s participation in the rating process, the non-participation designation will neither be considered a rating modifier, nor be considered a rating action,” said Mahoney. “It simply connotes that a rating was assigned without our having had recent analytic communication with the issuer.”