Subject: File No. 4-661
From: Takahiro Hirota

June 7, 2013

The role of Internal Audit in the Credit Ratings Industry is extraordinarily unique. As Credit Ratings Agencies are effectively both public and private vessels, the role could differ significantly from the rest of the financial world, and has to be elevated. In other words, it will have to work for the public, regulators, and finally the Credit Ratings Agency as the most independent control function with a humble and objective mindset.

Therefore, the following aspects could be integrated into the new global regulatory framework of the Internal Auditors operating in the Credit Ratings Industry.

First of all, Internal Auditors, who meet the qualifications outlined by the regulators, serve as independent board members of their Credit Ratings Agencies' entities that publish ratings at systemically important markets.

Secondly, the regulators choose identical samples of ratings published by a population of the Credit Ratings Agencies on a punctual basis (to prevent credit bubbles), and request Internal Auditors to make standard reporting about the sample ratings published by their Credit Ratings Agencies together with pre-defined supporting documentation. The regulators can follow up with a specific Credit Ratings Agency based on the reporting.

Lastly, the regulators assess both independence and objectivity of the Internal Auditors on a regular basis.

Thank you.