Subject: File No. 4-661
From: Paul Fosbre
Affiliation: Kean University

May 14, 2013

The sound connection was lost between 3:30PM and 3:54PM and then the sound resumed.

I will try to listen again to the broadcast.

Excellent Panel and well moderated by Thomas Butler.

I think there should be a discussion regarding the Accounting Impact for restricting revenue recognition by the rating agencies for a poor credit analysis.
These agencies are fee based with immediate accrual of fee
income earned. The problem with restricting revenue recognition is that the larger credit rating agencies will no longer be able to pay for their infrastructure and analysis. The SEC should not ruin the credit rating process that currently exists but rather seek to expand the options an issuer has to evaluate the credit worthiness of the asset securitization in order to insure a rigorous credit analysis.

Credit rating analysts are necessary for a successful and transparent credit analysis function.

The SEC examiners also need to be trained to further analyze these proprietary and non transparent credit rating models.

Open source credit models are not practical because of the lack of testing and the threat of both copyright and patent infringement. An open source model can also be changed to get the end result that is desired rather a thorough credit analysis and examination in the credit rating process.

The software in concert with human capital should produce the credit scoring and final analysis not some amateur untested credit scoring software model.

Rating Agency analysts may have been credit trained by a major financial institution without any certifications and may have been trained in house by the Big Three credit agencies.

Best Regards

Paul Fosbre