Subject: File No. S7-24-09
From: Stephen D Robbins

October 26, 2009

The proposed rule on Credit Ratings Disclosure is a weak attempt to restore integrity to credit ratings. The measures do not address the fundamental conflict of interest that is at the root of the problem.

The issue of "selling" credit ratings, as reported by McClatchy newspapers, is well known. (

As long as the company paying for the service has a vested interest in the result, there is a conflict of interest. And where there is a conflict of interest, there will be corruption.

My sister worked as an auditor for a nationally recognized auditing company many years ago. As she was told "The client is always at the top of the organization chart." The same attitude is true at debt rating agencies.

It is necessary to end the system whereby the company receiving the benefit of the rating pays the rating agency for its services. Rating agencies must receive compensation from independent parties: perhaps shareholders, stock exchanges, or the government, but NOT from the company benefiting from the rating.