Subject: File No. DF Title II - BD Liquidation
From: darrell k campbell, mba
Affiliation: private investor, pharmacist

January 20, 2011

ABS -Dodd Frank Rule Comment

One way to improve the performance landscape is to have a yearly certification of an agency( SP,moody,fitch, meredith whitney ,-others) that indicates their ability to assess (rate)corporate instruments.(much as they do to bonds, abs,et al)

Another bureaucracy is not needed. but it is OBVIOUS that these so called raters seriously lack or lacked the ability to perform unsupervised. Had they done their work with credibility and not to receive payoffs for the mbs, abs, et al they "rated", much of the pyramid of exotic creations would likely have been
curtailed. The public has yet to see any sanctions against any agency. Obviously such would undermine their credibility- New players are needed as well.

I would suggest a CPA and Chartered financial analyst team who are specialists in risk management. In this way the " credit agency" will be forced to strive to update based in a GLOBAL market and in the impact of the holding of any instrument where country risk, and corresponding systemic risk are assessed.

The world expects best practices from this country not huge losses which could have been curtailed with proper instrument assessment

A yearly recertification would greatly improve the worlds perception(of each). If nothing is done then other countries will start their own rating agencies.
there are after all only 3-4 so the task is not huge.

Otherwise the country runs the risk of having to form another agency as Eliz Warren is doing and playing hardball with many lenders shoddy practiices.

Call the ball and make it happen.