Subject: File No. S7-04-05
From: John M Fitzgerald, Esquire

June 9, 2005

To the extent that any rating agency rates multilateral development banks MDBs or political jurisdictions, or subsidiaries thereof, that ratings agency should be required to:

1 disclose the extent to which they have had, and the public has, access to independent audits of all internal controls and all internal financial statements, quantitative risk management assessments and scenarios, and capital adequacy tests;

2 disclose the manner and most recent months in which they have assessed and rated the risks of default by borrowers or non-accrual, pre-payment, under-replenishment, limitations on callable capital, currency variation, and liability of the issuer or its borrowers for financial losses and for damage awards or recovery as a result of corruption, mismanagement, negligence or strict liability exposure e.g., equity or debt positions in inherently dangerous activities; and major risk or loss drivers such as contributions to or risks resulting from climate change, and

3 disclose the extent to which it has considered whether each jurisdiction or MDB, according to such sources as the U.S. State and Treasury Departments, the MDBs analysis or that of the Government Accountability Office, meets transparency and accountability standards required of other issuers given similar ratings, such as COSO, the Sarbanes Oxley Act, or those established by the US Government, such as those of Section 1504 of the International Financial Institutions Act, and

4 disclose the extent to which the MDBs and their borrowers use natural resource and human resource accounting to provide clearer indications of stewardship, loss and replenishment of natural and human capital in credit and budget allocations.