Proposed Rules for Credit Rating Agencies - ACT Letter to SEC

Oversight of Credit Rating Agencies Registered as Nationally Recognized Statistical Rating Organizations

Our members generally are interested in credit rating agencies as both investors in and issuers of debt. Where there is any conflict between the financial services industry and their customers, We comment on financial market matters from the point of view of a nonfinancial corporation.

We have seen Professors Herwig and Patricia Langohr’s comments on the proposed rule making above.

We would like to express support for the points made by the Professors Langohr.

As the major agencies for the developed markets of the world are US-based, we consider it important to comment on the proposed rule making.