Subject: File No. S7-18-11
From: Kevin Overholt

June 14, 2011

I support the proposed rules for establishing a background and explanation for a proposed credit rating. However, even then there remains the opportunity for unethical integrity. I still see the problem of the ratings agencies being able to "fluff-up" their reports. Furthermore they could be provided with bad or misleading information by a client whose interests would be served by a better credit.

A solution that I can think of would, I suppose, at least minimize the chance for unethical practices. This proposal would/should be an independent, joint committee consisting of a reviewers from the private and government sectors, in addition to finding independent, outside economists to review the data.

I know this is a bit far from laissez-faire, but as we have seen in the last few years, on Wall Street and in the Government, honesty and transparency do not seem to be the Mode of Operation. Sadly, greed drives a lot of this. It is unfortunate that people will step on others to get ahead for themselves. If everyone had a little more concern for their neighbor/another average American, we would all be better off.

Thank you.