July 8, 2008
Dear Sir or Madam,
Please consider allowing a SEC representative discuss with the National Association of Insurance Commissioners ("NAIC") rule amendments that would be intended to reduce undue reliance in the Commission's rules on NRSRO ratings.
I am part of a NAIC Committee that is trying to reduce undue reliance on these ratings by insurance regulators. The Committee includes several industry representatives whom are resisting an increase in capital for structured securities. They argue that this is part of credit risk included in the NRSRO ratings. They agree that NRSRO ratings have not been without error, but look to the SEC to implement more stringent controls over them.
I hope that you will consider my invitation and welcome your advice.
Thank you, Elaine Wieche