Moody’s Investors Service is considering a plan to flag issuers who don’t cooperate in the rating process.

The rating’s agency is asking market players to comment on a proposal to identify rated issuers that do not participate in the rating process. Assuming it receives support for the proposal, Moody’s would begin designating such issuers later this year.

Moody’s said that this initiative is partly coming from regulators. It said that the role of rating agencies in the capital market is currently being considered by individual national regulators as well as the International Organization of Securities Commissioners, and that, as part of that discussion, there have been recommendations that rating agencies should identify those ratings which are assigned without issuer participation.

Christopher Mahoney, chairman of Moody’s Credit Policy Committee suggested that the move would increase transparency. “This proposal reflects the market’s desire for greater transparency,” he said.

When determining whether an issuer has participated in the rating process over the previous 12 months, Moody’s would define a “non-participating issuer” as an issuer that has declined to engage in communications with Moody’s on credit-related issues. Commercial discussions or comments on a proposed press release would not, however, be considered to be participation in the credit process. If there is disagreement on whether an issuer is participating in the process, Moody’s will generally defer to the issuer’s perspective in determining whether to designate the rating.

Moody’s noted that a large majority of its rated issuers do participate in the rating process, so few of its ratings would be affected by this change in policy. “In general, Moody’s and rated issuers agree that the ratings process benefits from issuer participation, as it allows them to provide their perspective and relevant information concerning their creditworthiness,” said Mahoney.

“However, some issuers choose not to participate for various reasons,” explains Mahoney, “and we would be prepared to identify such nonparticipants.” Moody’s said that all issuers are provided the opportunity to participate in the rating process.

Moody’s says that if it moves forward with this initiative, it would expect initially to publish a list of non-participating ratings for corporates, financial institutions, sovereigns, and structured issuers globally, and may extend the list at a later date to include the largest US public finance issuers. The rating agency asks that comments on any aspect of the proposal be forwarded by September 10.