We have published a whitepaper for Members of Congress on the credit rating agency issue. This is a continuation of the Comment Letters to the SEC and other written correspondence to Members of Congress on this topic.
We have proposed four legislative and regulatory measures which we believe will further enhance competition and transparency for credit rating agencies. These proposals are slight modifications or additions to the legislation passed in 2006, the Credit Rating Agency Reform Act.
++ Equivalent Disclosure
++ Grant the SEC authority to revoke NRSRO status
++ Create a central repository of default statistics at the SEC
++ Designate oversight of the NRSRO relationship to issuer audit committees
Here are the hyperlinks referenced in the whitepaper:
Page 5:
“A Sinking Sensation for Subprime Loans”
Page 6:
“Subprime Losses Drub Debt Securities”
“Rate Agencies Move Toward Downgrading”
Page 7:
“James Grant Says World Credit Market Has Yet to Reach Bottom”
“Ohio Attorney General Says Raters “Likely Aided and Abetted Fraud”"
“Florida Pension Fund Has `Suspect’ Debt Held by Pool”
Page 8:
“Mr. Josh Rosner of Graham Fisher discusses credit rating agencies”
Page 12:
“testimony of Professor John Coffee to the Senate Banking Committee”
Page 13:
“data from Moody’s 3Q 2007 10Q page 17”
Page 16:
“in his testimony of September 26, 2007 to the Senate Banking Committee”
Page 17:
“as the following in a letter to the SEC (Brian Clarkson of Moody’s)”
Page18:
in his testimony to the Senate Banking Committee (page 7).
Page 21:
“Committee on European Securities Regulators asked credit rating agencies”
Page 23:
“Moody’s Municipal Ratings Obscure Bond Safety, Citigroup Says”
Page 25:
“Chairman William Donaldson made the following remarks”
Page 26:
“wrote in the Wall Street Journal”
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Page 28:
Release No. 34-55231; File No. S7-04-07
solicited comments on the Proposed Rule
and published the Final Rule on June 5, 2007
Page 30:
Senate hearing (see hearing web cast and testimony here)
House hearing (seeing hearing web cast and testimony here)
SEC Chairman Cox stated the following in his testimony to the Senate Banking Committee
Page 31:
from John J. Goggins, Vice President and Associate General Counsel, Moody’s Investors Service
Page 33:
(AL) Former SEC Chairman Arthur Levitt
(AP) Alex Pollock
(CK) Chairman Kanjorski
(CL) Cate Long
(EM) Eric Mindich
(JC) John Coffee
(JM) Joe Mason
(SS) Senator Shelby
Page 34:
Primer on the US Treasury market:
Global underwriters of debt 3Q 2007
Bank of England Financial Stability Report (3Q 2007)
Moody’s written testimony to the House of Commons
Independent credit ratings research
Nationally Recognized Statistical Rating Organizations (NRSRO) have published their applications to be recognized by the SEC as required by law. Here are the links:
- AM Best
- Dominion Bond Rating Service
- Egan-Jones
- Fitch Ratings
- Japan Credit Rating Agency
- Moody’s Investor Services
- Ratings and Investment Information
- Standard & Poors
Minutes of evidence from representatives of rating firms taken before the Treasury Committee, House of Commons, Tuesday 13 November 2007
Transcript from the National Housing Forum held December 3, 2008 at the National Press Club, Washington, DC - 148 pages
http://www.reuters.com/article/economicNews/idUSN0342582020071203
Innovating Our Way to Financial Crisis Dec 3, 2007 (The New York Times) –
