The ACT is pleased that CESR is clear in distinguishing between the approach of the Agencies as to corporate / sovereign ratings compared with structured finance ratings. We note that other market participants have reinforced this distinction. We would strongly recommend that this distinction is maintained through any eventual recommendations CESR might make.
It is our view that the corporate ratings model serves issuers, investors and intermediaries equally well. We would be greatly concerned if any changes to the IOSCO Code of Conduct were proposed which added material costs, either direct or in management resource, to the relationship between the Agencies and corporate issuers.