March 3, 2011
I offer a comment in response to release 2011-59.
SEC Proposes Rule Amendments to Remove Credit Rating References in Investment Company Act Rules and Forms
I am an amateur investor. Mostly, I rely upon the advice of a certified professional advisor.
I have a beneficial suggestion that I want to bring to your attention. I believe that it has the potential to significantly reduce the likelihood of conflict of interest in the relationship of ratings agencies and accounting firms with their clients, the issuers of securities. It has the further advantage of being totally without cost to the public.
SUGGESTION: Rotate accountants. Any firm that issues securities to the public shall make a practice of changing its accountant periodically. I would say that every three years would be a reasonable period.
Because it will know that its successor will be a competitor and will have a fresh set of eyes to review its work, the current accountant will stay truly disinterested. The accountant's reputation will depend on passing to its successor a clean set of books. The beneficial result for the rest of us will be financial reports upon which investors will be able to rely with confidence.
The same arrangement will apply to bond-rating agencies, so long as they are truly competitive and concerned for their reputations.
NB: Compulsion by regulation is not required. I would recommend this proposal to any issuer of securities, with or without regulation. Alert investors will appreciate the simple protection against systematic fraud or misstatement and will reward the firm that adopts my rotating-acountants scheme with a premium for its securities. That effect alone should be enough to encourage voluntary adoption of the scheme.
: : We can't direct the wind,
: : but we can trim the sails.
* * * * * *