Subject: File No. S7-04-07
From: Ayal Rosenthal

March 12, 2007

To Whom It May Concern:

In response to the Commissions request for comments on the Credit Rating Agency Reform Act of 2006, I propose that Exhibit 3 require an NRSRO to specifically furnish its policies and procedures on its website for public consumption. Furthermore, I believe that exhibit 13 should be public information with regards to key analysts defined as the five analysts responsible for the largest five sectors in terms of revenues for each agency as well as the median pay of analysts. The median pay of analysts is relevant in order to analyze the ability of an agency to attract high quality employees.

I agree with the Commissions requirement that credit worthiness must be assigned to at least 85% of a products underlying assets and support its efforts to increase competition in the oligopoly-dominated credit ratings market.

Thank you for taking these comments into consideration,

Ayal Rosenthal