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