Subject: File No. 4-629
From: Donald C Huffaker, CPA, CFA

May 10, 2011

I first start with an observation of the two main means to attempt to manage risk - diversification and knowledge. While not perfect, the NRSROs did provide knowledge. It was up to the investor to independently ascertain whether the credit risk is compatible with the investor's risk tolerance. Eliminating use of NRSROs removes a source of information, making transactions and portfolio potently more risky.

Despite protestations, there is an inherent conflict with receiving payment from the client supposedly being rated. The converse - having investors foot the bill - cretes t eh opposite issue - the best knowledge becomes inequitably delivered. Threfore, we aqre looking for a different model. As a compromise, have an independent agency assign the NRSROs to the public companies, but the public companies still foot the bill. This will prevent cherry picking and potentially prevent mis-guided opinions as the fear of removal over disagreements.