Subject: File No. S7-18-11
Affiliation: ISACA , IIA

May 19, 2011

In order to reduce the conflict of interest which is always part of credit rating agencies and their work a lot of accountability and self-assessment can be introduce in rating processing by doing periodic auditing and assessment of rating decision and the rationale behind them by SEC and/or third party. This will ensure that the Credit rating agencies will spend more time and efforts to build their internal control and compliance process and strengthen their control environment. Even thou the control is detective, its preventive in nature to mature the rating process over a period of time.