Subject: S7-11-22: WebForm Comments from Bradford Ferguson
From: Bradford Ferguson
Affiliation: Chief Investment Strategist, CFA Charterholder

May. 20, 2022

 


 May 20, 2022

 I am for this proposal.

Credit ratings continue to be unresponsive to changes in market conditions. Overly conservative practices perhaps corrupted by payments for ratings creates a bias that investment professionals no longer rely on nor should fiduciaries be forced to take into account.

With the widespread nature of information, credit ratings are no longer need, opinion on investments and credit metrics are widely available.

An example. imo, The credit rating for Tesla is a joke. Tesla has $18 billion in cash and less than $100 million in non-asset backed debt (not auto loans/leases which are backed by the cars) and Tesla is rated as not investment grade. Tesla DOMINATES all other large automakers on credit metrics yet only Honda is also not investment grade. This is a farce.

Credit ratings should neither be referenced nor mandated by governments. I support the proposed change. Thank you. -Bradford Ferguson