TAILIEUCHUNG - Summary Report of Issues Identified in the Commission Staff’s Examinations of Select Credit Rating Agencies

The studies that have entered the public domain have been largely inconclusive or suffer from serious methodological deficiencies. A study funded by the American Insurance Association (AIA), an industry trade association, found no correlation between income and credit scores (AIA, 1998). However, the AIA study appears to suffer from methodological flaws so serious that no conclusions are warranted. 8 The Virginia Bureau of Insurance sponsored a study based on ZIP Code aggregates. Unfortunately, the numeric results of the analysis were never publicly released. Rather, the. | Summary Report of Issues Identified in the Commission Staff s Examinations of Select Credit Rating Agencies By the Staff of the Office of Compliance Inspections and Examinations Division of Trading and Markets and Office of Economic Analysis UNITED STATES SECURITIES AND EXCHANGE COMMISSION July 2008 TABLE OF CONTENTS I. II. A. The B. Current Regulatory Requirements and Proposed New Rules and Rule Amendments With Respect to Credit Rating III. The Ratings A. The Creation of RMBS and B. Determining Credit Ratings for RMBS and IV. The Staff s Examinations Summary of Factual Findings Observations and A. There was a Substantial Increase in the Number and in the Complexity of RMBS and CDO Deals Since 2002 and Some Rating Agencies Appeared to Struggle with the B. Significant Aspects of the Ratings Process Were Not Always C. Policies and Procedures for Rating RMBS and CDOs Can be Better D. Rating Agencies are Implementing New Practices with Respect to the Information Provided to E. Rating Agencies Did Not Always Document Significant Steps in the Ratings Process -- Including the Rationale for Deviations From Their Models and for Rating Committee Actions and Decisions -- and They Did Not Always Document Significant Participants in the Ratings F. The Surveillance Processes Used by the Rating Agencies Appear to Have Been Less Robust Than Their Initial Ratings G. Issues Were Identified in the Management of Conflicts of Interest and Improvements Can be 1. The Issuer Pays 2. Analysts 3. Securities Transactions by Employees of Credit Rating H. Internal Audit V. Observations by the Office of Economic A. Conflicts of Interest. 31 B. Factual Summary of the Ratings Process for 1. Risk 2. Use of Historical 3. Surveillance of .

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