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,