Press Release

Press Release

May 21, 2026

JAIPUR VIDYUT VITRAN NIGAM LIMITED
Rating Assigned and Reaffirmed

Product	Quantum (Rs. Cr) (SEBI)	Quantum (Rs. Cr) (Other FSR)	Long Term Rating	Short Term Rating	Regulated By
Bank Loan Ratings	0.00	2126.30	ACUITE BBB+ \| Stable \| Assigned	-	RBI
Bank Loan Ratings	0.00	2907.50	ACUITE BBB+ \| Stable \| Reaffirmed	-	RBI
Bank Loan Ratings	0.00	1533.65	-	ACUITE A2 \| Reaffirmed	RBI
Total Outstanding	0.00	6567.45	-	-	-
Total Withdrawn	0.00	0.00	-	-	-

Note:- For activities or ratings of instruments falling under the purview of Financial Sector Regulators other than SEBI, the grievance / dispute redressal mechanisms and investor protection mechanisms provided by SEBI shall not be available.

Rating Rationale

Acuité has reaffirmed its long-term rating of 'ACUITE BBB+' (read as ACUITE triple B plus) and its short-term rating of 'ACUITE A2' (read as ACUITE A two) on Rs. 4441.15 Cr. bank facilities of Jaipur Vidyut Vitran Nigam Limited (JVVNL). The outlook is 'Stable'.
Also, Acuité has assigned its long-term rating of 'ACUITE BBB+' (read as ACUITE triple B plus) on Rs. 2126.30 Cr. bank facilities of Jaipur Vidyut Vitran Nigam Limited (JVVNL). The outlook is 'Stable'.

Rationale for rating
The rating factors in the strategic importance of JVVNL for Government of Rajasthan (GoR) and the support it receives from the State in the form of subsidies, grants and government guarantee backed borrowings. Further, the rating considers the reduction in the AT&C and T&D losses supported by improvement in their collection and billing efficiency as reflected in 9MFY26. Further, the rating is constrained on account of financial risk profile marked by negative net worth, and deterioration in the debt protection metrics given the high debt levels of the company along with regulated nature of business.

About the Company

Incorporated in 2000, Jaipur Vidyut Vitran Nigam Limited (JVVNL) is a state power distribution company of Rajasthan State Electricity Board (RSEB). The Jaipur discom has been created with the principal objective of engaging in the business of distribution and supply of electricity in 15 districts of Rajasthan, namely Jaipur, Dausa, Alwar, Bharatpur, Dholpur, Kota, Bundi, Baran, Jhalawar, Sawaimadhopur, Tonk, Karauli, Bhiwadi, Deeg and Kotputli. The company has its registered office located in Jaipur. The current directors of the company are Mrs. Aparna Arora, Mr. Raj Kumar Sharma, Mr. Sidharth Sihag, Mr. Hemant Das, Mrs. Arti Dogra, Mr. Harsh Baweja, Mr. Naveen Jain.

Unsupported Rating

ACUITE BB/Stable/A4

Analytical Approach

Acuité has considered the standalone business and financial risk profile of Jaipur Vidyut Vitran Nigam Limited (JVVNL) to arrive at the rating. Further, Acuité has also factored in the inherent support extended from the state Government of Rajasthan (GoR).

Key Rating Drivers

Strengths

Strategic relevance of JVVNL for state government and financial support extended by the state
Established by the State Government of Rajasthan, JVVNL forms the backbone of the power sector infrastructure for Rajasthan by covering operations for 15 districts of the state. The Government of Rajasthan (GoR) has consistently supported JVVNL through regular fund infusions in the form of equity, grants, and subsidies along with corporate guarantees. JVVNL's credit profile is also supported by its access to funds at low cost and its ability to mobilise financial resources from several financial institutions and multilateral development institutions. The financial support along with well-established regulatory framework including multi-year tariff regulations and sanctioned grants has strengthened the operations of JVVNL. During FY25, JVVNL received Rs. 11,276 Cr. of grants from the state as compared to Rs. 10,725 Cr. in FY25. Further, under the additional borrowing limit of 0.50% of Gross State Domestic Product (GSDP) scheme, State Government has agreed to take over the future five-year losses of the discom in a phased manner, and as per guidelines, GoR has taken over and in lieu of that released a sum equivalent to 100% of the losses reported in FY25.
Acuité believes that JVVNL, being a fully owned undertaking of GoR, shall continue to benefit from the financial, operational and management support of GoR from time to time. Any event that impinges GoR's overall credit profile shall remain a key rating sensitivity.

Continued reduction in AT&C and T&D losses and reduced ACS-ARR gap in 9MFY26
The operating performance of the company is highly dependent on technical parameters including aggregate technical & commercial (AT&C) and transmission & distribution (T&D) losses, billing and collection efficiency along with gap between average cost of supply (ACS) and average revenue realised (ARR). The collection efficiency stood at 99.32 percent in 9MFY26 (99.46 percent in FY25 and 94.91 percent in FY24) and the billing efficiency stood at 89.24 percent in 9MFY26 (86.25 percent in FY25 and 84.23 percent in FY24). Therefore, the AT&C losses stood improved at 11.37 percent in 9MFY26 (14.22 percent in FY25 and 20.05 percent in FY24). Further, the T&D losses stood improved at 17.46 percent in 9MFY26 (21.20 percent in FY25 and 22.19 percent in FY24). Moreover, the ACS-ARR gap stood reduced at Rs. 0.05 per unit in 9MFY26 (Rs. 0.38 per unit in FY25 and Rs. 0.30 per unit in FY24) on account of surcharge implemented by RERC of Rs. 0.70 to Rs. 1 per unit since October 2025.

Weaknesses

Average financial risk profile
The financial risk profile remains modest marked by negative net worth and deterioration in the coverage indicators. The discom reported net losses in FY25 that resulted in further decline in the net worth. The debt levels stood similar at Rs. 35,569.36 Cr. as on March 31, 2025 (Rs. 34,012.24 Cr. as on March 31, 2024) due to the highly capital-intensive nature of business wherein to maintain the operational efficiencies, the company has to regularly incur capital expenditures. This higher debt has resulted in the deterioration of the debt protection metrics, reflected by moderate interest coverage ratio (ICR) of 1.14 times in FY25 (1.32 times in FY24) and below unity debt service coverage ratio (DSCR) of 0.45 times in FY25 (0.58 times in FY24). While the company’s DSCR has been weak in the past three years ended FY25, Acuité notes that JVVNL has received regular support from GoR in the form of grants and equity infusion to support their operations which is expected to continue going forward.

Regulated nature of operations
The revenues are influenced by the regulatory framework governing the power sector. The revenues of players such as JVVNL are determined by Rajasthan Electricity Regulatory Commission (RERC) through revision in tariff. Any significant delays in tariff approvals or a reduction in return on equity or a tightening of the RERC norms could result in lower operating cash flows.

Assessment of Adequacy of Credit Enhancement under various scenarios including stress scenarios (applicable for ratings factoring specified support considerations with or without the “CE” suffix)

JVVNL has been supported by Government of Rajasthan (GOR) through 100 percent holding and regular support in the form of timely disbursals of subsidies, grants and guarantees backed borrowings. GoR grants and subsidies would help augment cash flows to ensure timely repayment of debt even in stress scenario.

Rating Sensitivities

Potential triggers (individual or collective) for an upward rating action:

Improvement in credit profile of GoR
Reduction in debt levels thereby improving financial risk profile with DSCR improving above 1.00 times??????

Potential triggers (individual or collective) for a downward rating action:

Deterioration in credit risk profile of GoR
Deterioration of operating performance with increase in AT&C losses above 15 percent or widening of ACS-ARR gap

Liquidity Position

Adequate

The liquidity position of the company stood adequate marked by timely repayment of the maturing debt obligations of the company on account of support extended by GoR in the form of grants and subsidies. Going forward, the maturing obligations shall be repaid by way of newly availed working capital loans which are backed by government guarantee and remaining by the way of grants from GoR. The cash flows are utilised as per the pre-defined waterfall mechanism with the priorities of payment of interest and principal obligations, statutory liabilities and then for the day-to-day operations of the company. Further, the cash and bank balances of the company stood healthy at Rs. 403.37 Cr. as on March 31, 2025 (Rs. 127.61 Cr. as on March 31, 2024). Further, Acuité receives comfort from the fact that JVVNL being a GoR entity warrants adequate financial support from GoR, time to time, to support the mismatches.

Outlook: Stable

Other Factors affecting Rating

None

Key Financials

Particulars	Unit	FY 25 (Actual)	FY 24 (Actual)
Operating Income	Rs. Cr.	28153.66	28654.10
PAT	Rs. Cr.	(706.49)	(27.13)
PAT Margin	(%)	(2.51)	(0.09)
Total Debt/Tangible Net Worth	Times	(2.97)	(2.87)
PBDIT/Interest	Times	1.14	1.32

Status of non-cooperation with previous CRA (if applicable)

Not Applicable

Any other information

None

Applicable Criteria

• Default Recognition :- https://www.acuite.in/view-rating-criteria-52.htm
• Infrastructure Sector: https://www.acuite.in/view-rating-criteria-51.htm
• Application Of Financial Ratios And Adjustments: https://www.acuite.in/view-rating-criteria-53.htm
• Group And Parent Support: https://www.acuite.in/view-rating-criteria-47.htm
• State Government Ratings : https://www.acuite.in/view-rating-criteria-26.htm

Note on complexity levels of the rated instrument

In order to inform the investors about complexity of instruments, Acuité has categorized such instruments in three levels: Simple, Complex and Highly Complex. Acuite’s categorisation of the instruments across the three categories is based on factors like variability of the returns to the investors, uncertainty in cash flow patterns, number of counterparties and general understanding of the instrument by the market. It has to be understood that complexity is different from credit risk and even an instrument categorized as 'Simple' can carry high levels of risk. For more details, please refer Rating Criteria “Complexity Level Of Financial Instruments” on www.acuite.in.

Rating History

Date	Name of Instruments/Facilities	Term	Amount (Rs. Cr)	Rating/Outlook
06 Oct 2025	Letter of Credit	Short Term	275.65	ACUITE A2 (Reaffirmed)
	Letter of Credit	Short Term	958.00	ACUITE A2 (Reaffirmed)
	Proposed Long Term Bank Facility	Long Term	669.60	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	171.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Working Capital Term Loan	Long Term	249.79	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	208.05	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	164.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	20.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	1000.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Cash Credit	Long Term	500.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Secured Overdraft	Long Term	100.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	125.06	ACUITE BBB+ \| Stable (Reaffirmed)
10 Jul 2024	Letter of Credit	Short Term	782.35	ACUITE A2 (Reaffirmed)
	Letter of Credit	Short Term	175.65	ACUITE A2 (Reaffirmed)
	Bank Guarantee (BLR)	Short Term	0.15	ACUITE A2 (Reaffirmed)
	Letter of Credit	Short Term	275.65	ACUITE A2 (Reaffirmed)
	Term Loan	Long Term	208.05	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	230.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	20.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Secured Overdraft	Long Term	100.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	333.36	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	234.75	ACUITE BBB+ \| Stable (Reaffirmed)
	Working Capital Term Loan	Long Term	367.95	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	186.39	ACUITE BBB+ \| Stable (Reaffirmed)
	Proposed Long Term Bank Facility	Long Term	26.85	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	979.81	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	20.19	ACUITE BBB+ \| Stable (Reaffirmed)
	Cash Credit	Long Term	500.00	ACUITE BBB+ \| Stable (Reaffirmed)
26 Jun 2024	Letter of Credit	Short Term	100.00	ACUITE A2 (Reaffirmed)
	Letter of Credit	Short Term	526.87	ACUITE A2 (Reaffirmed)
	Letter of Credit	Short Term	175.65	ACUITE A2 (Reaffirmed)
	Bank Guarantee (BLR)	Short Term	0.15	ACUITE A2 (Reaffirmed)
	Cash Credit	Long Term	100.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	333.02	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	279.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	20.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Secured Overdraft	Long Term	100.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	500.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	282.00	ACUITE BBB+ \| Stable (Reaffirmed)
	Working Capital Term Loan	Long Term	465.25	ACUITE BBB+ \| Stable (Reaffirmed)
	Term Loan	Long Term	315.59	ACUITE BBB+ \| Stable (Reaffirmed)
	Proposed Long Term Bank Facility	Long Term	263.81	ACUITE BBB+ \| Stable (Reaffirmed)
29 Mar 2023	Letter of Credit	Short Term	526.87	ACUITE A2 (Assigned)
	Letter of Credit	Short Term	175.65	ACUITE A2 (Assigned)
	Bank Guarantee (BLR)	Short Term	0.15	ACUITE A2 (Assigned)
	Letter of Credit	Short Term	100.00	ACUITE A2 (Assigned)
	Term Loan	Long Term	20.00	ACUITE BBB+ \| Stable (Assigned)
	Secured Overdraft	Long Term	100.00	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	500.00	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	282.00	ACUITE BBB+ \| Stable (Assigned)
	Working Capital Term Loan	Long Term	465.25	ACUITE BBB+ \| Stable (Assigned)
	Cash Credit	Long Term	100.00	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	333.02	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	279.00	ACUITE BBB+ \| Stable (Assigned)
	Term Loan	Long Term	315.59	ACUITE BBB+ \| Stable (Assigned)
	Proposed Long Term Bank Facility	Long Term	263.81	ACUITE BBB+ \| Stable (Assigned)

Annexure - Details of instruments rated

Lender’s Name	ISIN	Facilities	Listing Status	Regulated By	Date Of Issuance	Coupon Rate	Maturity Date	Quantum (Rs. Cr.)	Complexity Level	Rating
State Bank of India	Not avl. / Not appl.	Cash Credit	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	Not avl. / Not appl.	500.00	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
BANK OF INDIA (BOI)	Not avl. / Not appl.	Letter of Credit	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	Not avl. / Not appl.	275.65	Simple	ACUITE A2 \| Reaffirmed
State Bank of India	Not avl. / Not appl.	Letter of Credit	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	Not avl. / Not appl.	1258.00	Simple	ACUITE A2 \| Reaffirmed
Not Applicable	Not avl. / Not appl.	Proposed Long Term Bank Facility	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	Not avl. / Not appl.	41.74	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
BANK OF INDIA (BOI)	Not avl. / Not appl.	Secured Overdraft	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	Not avl. / Not appl.	100.00	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
INDIAN OVERSEAS BANK	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	25 Jun 2028	143.98	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
Indian Bank	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	01 Apr 2033	500.00	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
Indian Bank	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	30 Nov 2037	273.70	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
State Bank of India	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	29 Feb 2032	1000.00	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
State Bank of India	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	13 Jul 2028	140.00	Simple	ACUITE BBB+ \| Stable \| Reaffirmed
Indian Bank	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	30 Nov 2037	1126.30	Simple	ACUITE BBB+ \| Stable \| Assigned
State Bank of India	Not avl. / Not appl.	Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	28 Sep 2033	1000.00	Simple	ACUITE BBB+ \| Stable \| Assigned
Punjab and Sind Bank	Not avl. / Not appl.	Working Capital Term Loan	Unlisted	RBI	Not avl. / Not appl.	Not avl. / Not appl.	28 Aug 2028	208.08	Simple	ACUITE BBB+ \| Stable \| Reaffirmed

*Annexure 2 - List of Entities (applicable for Consolidation or Parent / Group / Govt. Support)

Sr. No.	Name of the Companies
1.	Government of Rajasthan
2.	Jaipur Vidyut Vitran Nigam Limited

Contacts

Mohit Jain
Chief Analytical Officer - Rating Operations

Akshit Agrawal
Associate Analyst - Rating Operations

Contact details exclusively for investors and lenders

Mob: +91 8591310146
Email ID: analyticalsupport@acuite.in

List of instruments and names of regulators of the instruments

As required by SEBI Circular (SEBI/HO/DDHS/DDHS-PoD-2/I/4685/2026) dated February 10, 2026, a list of activities or instruments falling under the purview of various Financial Sector Regulators (FSRs), along with the names of respective FSRs, is being disclosed below:
A. Rating Activity:

Sr. No.	Instrument / activity Name	Regulator of the instrument
1	Listed/Proposed to be listed Bonds/Debentures/Preference Shares (all securities)	SEBI
2	Unlisted/Proposed to be unlisted Bonds/Debentures/ Preference share (all securities)	MCA
3	Listed PTCs / Securitisation Notes (originated by entities regulated by RBI)¹	SEBI
4	Listed PTCs / Securitisation Notes (originated by entities not regulated by RBI)¹	SEBI
5	Unlisted PTCs / Securitisation Notes (originated by entities regulated by RBI)¹	RBI
6	Listed Commercial Paper and NCDs with original maturity less than 1 year	RBI
7	Unlisted Commercial Paper and NCDs with original maturity less than 1 year	RBI
8	Loan Facilities (Fund/Non-Fund Based) from Bank / NBFCs/ NHB/ FIs ²	RBI
9	External Commercial Borrowings and other similar borrowings	RBI
10	Certificates of Deposit	RBI
11	Fixed Deposits raised by NBFCs, Banks, HFCs, FIs	RBI
12	Fixed Deposits raised by corporates other than NBFCs, Banks, HFCs, FIs	MCA
13	Inter Corporate Deposits/Loans extended by Corporates	MCA
14	Borrowing programme ³	-
15	Issuer Ratings ⁴	-
16	Credit Ratings for Capital Protection Oriented Schemes (by Mutal Funds and AIFs)	SEBI
17	Credit quality ratings (CQRs) for Mutual Fund Schemes and Schemes of AIFs	SEBI
18	Listed Security Receipts	SEBI
19	Unlisted Security Receipts	RBI
20	Independent Credit Evaluation (ICE)	RBI
21	Expected Loss Ratings (For Loan Facilities [Fund/Non-Fund based] from Banks/NBFCs/NHB/FIs)	RBI
22	Expected Loss Ratings (Listed / Proposed to be listed Bonds / Debentures / Preference Shares (all securities))	SEBI
23	Expected Loss Ratings (Unlisted / Proposed to be unlisted Bonds/ Debentures / Preference Shares (all securities))	MCA
24	Unlisted PTCs / Securitisation Notes (originated by entities not regulated by RBI) ¹	Investor-side Regulator such as IRDAI, PFRDA ⁵

¹Includes securitisation transactions involving assignee payout, acquirer's payout.

² Includes bank facilities such as liquidity facility, second loss facility that are part of securitisation transactions.
³The rated instrument may involve issuance of different instruments such as debt securities (listed or otherwise), bank loans, commercial paper (listed or otherwise), etc. The regulator of the instrument may accordingly be SEBI, RBI or MCA and can only be determined upon issuance. In Press Release(s) subsequent to issuance(s), Acuite shall separately capture the rated quantum details along with names of respective regulators.
⁴ There is no instrument being rated and hence, Regulator of the Instrument is not applicable. The rating scale and definitions are being followed as stipulated in SEBI Master Circular for CRAs.
⁵ These ratings were assigned during regulatory regime prior to the introduction of SEBI CRA Circular dated Feb 10, 2026 and accordingly, investor side regulators have been included.

B. Other activities:

Sr. No.	Activity Name	Regulator of the activity
1	Monitoring Agency	SEBI
2	Research activities, incidental to rating, such as research for Economy, Industries and Companies ⁶	Not applicable

⁶ permitted by SEBI vide SEBI Master Circular for CRAs.

Disclosure on instruments / activities and names of regulators:

A list of products/activities or ratings of instruments falling under the purview of various financial sector regulators (FSRs) along with the names of respective FSRs has also been duly disclosed by Acuite on its website. A link to the same has been provided below for ready reference:

https://acuite.in/Activities-and-Regulators.html

About Acuité Ratings & Research

Acuité is a full-service Credit Rating Agency registered with the Securities & Exchange Board of India (SEBI). The company received RBI Accreditation as an External Credit Assessment Institution (ECAI) for Bank Loan Ratings under BASEL-II norms in the year 2012. Acuité has assigned ratings to various securities, debt instruments and bank facilities of entities spread across the country and across a wide cross section of industries. It has its Registered and Head Office in Kanjurmarg, Mumbai.

Disclaimer: An Acuité rating does not constitute an audit of the rated entity and should not be treated as a recommendation or opinion that is intended to substitute for a financial adviser's or investor's independent assessment of whether to buy, sell or hold any security. Ratings assigned by Acuité are based on the data and information provided by the issuer and obtained from other reliable sources. Although reasonable care has been taken to ensure that the data and information is true, Acuité, in particular, makes no representation or warranty, expressed or implied with respect to the adequacy, accuracy or completeness of the information relied upon. Acuité is not responsible for any errors or omissions and especially states that it has no financial liability whatsoever for any direct, indirect or consequential loss of any kind, arising from the use of its ratings. Ratings assigned by Acuité are subject to a process of surveillance which may lead to a revision in ratings as and when the circumstances so warrant. Please visit our website (www.acuite.in) for the latest information on any instrument rated by Acuité. Please visit https://www.acuite.in/faqs.htm to refer FAQs on Credit Rating.

Note: None of the Directors on the Board of Acuité Ratings & Research Limited are members of any rating committee and therefore do not participate in discussions regarding the rating of any entity.