Credit Ratings Regulation - Comment Letter - Morningstar - August 8, 2011

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Dodd-Frank Timeline, NRSROs, SEC
Proposal Date Final Rule Issue Effective Date
June 8, 2011 September 15, 2014 November 14, 2014

Nationally Recognized Statistical Rating Organizations
August 8, 2011

From the comment letter:

"As references to credit ratings have been removed from the federal securities laws, and if additional regulatory burdens are set at a level too burdensome or costly, it is possible certain smaller NRSROs3 will deregister and competitors will be discouraged from obtaining the NRSRO designation. We believe that the rules or guidance issued should balance the need for greater regulation in the industry with the simultaneous need to create more competition in the credit rating industry."

Morningstar specifically expresses concerns with, among other things, internal controls, the look-back review, fines, and the proposed disclosure of information about the performance of credit ratings.


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