Subject: File No. 4-629
From: Adrian Burridge

May 10, 2011

Rating agencies should not be allowed to rate both the structured product and the underlying security that the structured product derives its value from.

One but not both, as the question becomes which fee are they representing and/or rating, the derivative or the physical.

Are the underlying not being downgraded to protect the derivatives?

This becomes especially prominent if one security - say the US treasury - is being used to fund or create the synthetic or structured product.

AIG and the Housing giants would be a representation of this shortcoming.

Yours Sincerely,

Adrian Burridge
President Inc.