Is there cyclical bias in bank holding company risk ratings?

This paper examines whether bank holding company (BHC) risk ratings are asymmetrically assigned or biased over business cycles from 1986 to 2003. In a model of ratings determination which accounts for bank characteristics, financial market conditions, past supervisory information, and aggregate macro-economic factors, we find that bank exam ratings exhibit inter-temporal characteristics. First, exam ratings exhibit some evidence of examiner bias for several periods analyzed. When the business cycle turns, examiners sometime depart from standards that they set during the previous phases of the cycle. However, this bias is not widespread or systematic. Second, exam ratings exhibit some inertia. Our results suggest that examiners rate on the side of not changing (rather than upgrading or downgrading) an institution's exam rating. Third, we find robust evidence of a secular trend towards more stringent examination BHC ratings standards over time.