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	<title>Comments for The Ratings Debate</title>
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		<title>Comment on TÜSİAD Scrutinizes Rating Agencies by Kai Werner</title>
		<link>http://www.theratingsdebate.com/tusiad-scrutinizes-rating-agencies/comment-page-1/#comment-8319</link>
		<dc:creator>Kai Werner</dc:creator>
		<pubDate>Sun, 29 Jan 2012 10:51:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=1029#comment-8319</guid>
		<description>wow, awesome blog.</description>
		<content:encoded><![CDATA[<p>wow, awesome blog.</p>
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		<title>Comment on OK, Agencies, Your Turn&#8230; by Jenaya</title>
		<link>http://www.theratingsdebate.com/ok-agencies-your-turn/comment-page-1/#comment-7789</link>
		<dc:creator>Jenaya</dc:creator>
		<pubDate>Tue, 10 Jan 2012 11:33:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=595#comment-7789</guid>
		<description>At last some ratianolity in our little debate.</description>
		<content:encoded><![CDATA[<p>At last some ratianolity in our little debate.</p>
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		<title>Comment on Bank Regulators Want Less Reliance on Rating Agencies by johnathan</title>
		<link>http://www.theratingsdebate.com/bank-regulators-want-less-reliance-on-rating-agencies/comment-page-1/#comment-5589</link>
		<dc:creator>johnathan</dc:creator>
		<pubDate>Thu, 15 Sep 2011 17:31:32 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=924#comment-5589</guid>
		<description>I am pursuing my Undergraduate degree in Banking &amp; Finance, and wanted to do my Thesis on some regarding CRA&#039;s. However all the issues seem to be covered already.
What are some thought provoking questions that you could offer, to help me discover an issue that I can work on regarding credit rating agencies?</description>
		<content:encoded><![CDATA[<p>I am pursuing my Undergraduate degree in Banking &#038; Finance, and wanted to do my Thesis on some regarding CRA&#8217;s. However all the issues seem to be covered already.<br />
What are some thought provoking questions that you could offer, to help me discover an issue that I can work on regarding credit rating agencies?</p>
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		<title>Comment on FOX Business Wonders Whether U.S. Deserves Its AAA by George A. Marshall</title>
		<link>http://www.theratingsdebate.com/fox-business-wonders-whether-u-s-deserves-its-aaa/comment-page-1/#comment-2818</link>
		<dc:creator>George A. Marshall</dc:creator>
		<pubDate>Tue, 12 Apr 2011 18:41:06 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=1031#comment-2818</guid>
		<description>Dagen MacDowell interviewed a guest  whose comments focused on Social Security, Medicare and Medicaid as the mai culprets with respect to the U.S. budjet and deficiet problems.

Actually, Social Security has been paying it&#039;s own way until recently.  The problem which should be attacked is the giant increase in the federal budget and debt during the last two years unrelated to entitlement spending.  Oboma has doubled the size of the EPA whose job it is to inhibit the development of U.S. energy resources. 

Address the current huge increase in the size of government then deal with entitlements.</description>
		<content:encoded><![CDATA[<p>Dagen MacDowell interviewed a guest  whose comments focused on Social Security, Medicare and Medicaid as the mai culprets with respect to the U.S. budjet and deficiet problems.</p>
<p>Actually, Social Security has been paying it&#8217;s own way until recently.  The problem which should be attacked is the giant increase in the federal budget and debt during the last two years unrelated to entitlement spending.  Oboma has doubled the size of the EPA whose job it is to inhibit the development of U.S. energy resources. </p>
<p>Address the current huge increase in the size of government then deal with entitlements.</p>
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		<title>Comment on Portugal’s Finance Minister Blames Ratings Agencies by FinWeek</title>
		<link>http://www.theratingsdebate.com/portugal%e2%80%99s-finance-minister-blames-ratings-agencies/comment-page-1/#comment-2505</link>
		<dc:creator>FinWeek</dc:creator>
		<pubDate>Sun, 27 Mar 2011 14:56:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=708#comment-2505</guid>
		<description>Really the situation in European Union is quite dangerous, due to the debt crisis in Portugal, Greece and Ireland. The European Comission should take care about this.</description>
		<content:encoded><![CDATA[<p>Really the situation in European Union is quite dangerous, due to the debt crisis in Portugal, Greece and Ireland. The European Comission should take care about this.</p>
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		<title>Comment on New Law Changes Liability Standard for Rating Agencies by María</title>
		<link>http://www.theratingsdebate.com/new-law-changes-liability-standard-for-rating-agencies/comment-page-1/#comment-1465</link>
		<dc:creator>María</dc:creator>
		<pubDate>Thu, 04 Nov 2010 23:54:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=928#comment-1465</guid>
		<description>Hi! I am a colombian student working on the rating theme in Colombia and I´m interested in studying this new bill, where can I find it? Can you send it to me?

Thank you very much!
Maria</description>
		<content:encoded><![CDATA[<p>Hi! I am a colombian student working on the rating theme in Colombia and I´m interested in studying this new bill, where can I find it? Can you send it to me?</p>
<p>Thank you very much!<br />
Maria</p>
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		<title>Comment on Jules Kroll Launches New Rating Agency by James A. Donald</title>
		<link>http://www.theratingsdebate.com/jules-kroll-launches-new-rating-agency/comment-page-1/#comment-1179</link>
		<dc:creator>James A. Donald</dc:creator>
		<pubDate>Sun, 19 Sep 2010 03:40:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=889#comment-1179</guid>
		<description>&quot;If Kroll is better, everyone will use them.&quot;

No they will not.  You use the ratings the regulators tell you to use.  If Kroll&#039;s ratings are politically incorrect, no one will dare use them.  If, then, the regulators tell banks to loan large sums of money to members of non asian minorities with no income, no job, and no assets, Kroll will rate those loans as just fine.</description>
		<content:encoded><![CDATA[<p>&#8220;If Kroll is better, everyone will use them.&#8221;</p>
<p>No they will not.  You use the ratings the regulators tell you to use.  If Kroll&#8217;s ratings are politically incorrect, no one will dare use them.  If, then, the regulators tell banks to loan large sums of money to members of non asian minorities with no income, no job, and no assets, Kroll will rate those loans as just fine.</p>
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		<title>Comment on OK, Agencies, Your Turn&#8230; by Cate Long</title>
		<link>http://www.theratingsdebate.com/ok-agencies-your-turn/comment-page-1/#comment-140</link>
		<dc:creator>Cate Long</dc:creator>
		<pubDate>Fri, 20 Nov 2009 00:59:16 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=595#comment-140</guid>
		<description>Excellent approach by the FDIC... kudos to them for their willingness to try a new approach... very creative!

OT.... and FYI...

http://www.nytimes.com/2009/11/20/business/global/20rating.html?ref=business</description>
		<content:encoded><![CDATA[<p>Excellent approach by the FDIC&#8230; kudos to them for their willingness to try a new approach&#8230; very creative!</p>
<p>OT&#8230;. and FYI&#8230;</p>
<p><a href="http://www.nytimes.com/2009/11/20/business/global/20rating.html?ref=business" rel="nofollow">http://www.nytimes.com/2009/11/20/business/global/20rating.html?ref=business</a></p>
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		<title>Comment on Check and Double Check by Cate Long</title>
		<link>http://www.theratingsdebate.com/check-and-double-check/comment-page-1/#comment-81</link>
		<dc:creator>Cate Long</dc:creator>
		<pubDate>Mon, 02 Nov 2009 13:10:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?p=509#comment-81</guid>
		<description>Exposing ratings performance to public scrutiny is one of the most powerful parts of the rulemaking the SEC has undertaken.

Moodys former compliance officer testified to the House Oversight and Reform Committee last month that Moodys did no surveillance of its muni ratings. They issued them and then left them static although they continued to bill the issuer.

This means that retail investors who were sold those securities had no specific or general sense of the accuracy of the rating or the pricing that derived from the rating.

I&#039;m sure that once the ratings are available for analysis we will see lots of market and academic scrutiny of ratings accuracy.  Long overdue.

The SEC is requiring the raters to expose the histories in XBRL for more ready comparison. Here is a presentation that I gave at a conference at the FDIC last month on the topic:

http://shopyield.com/2009/10/06/xbrl-and-credit-ratings/</description>
		<content:encoded><![CDATA[<p>Exposing ratings performance to public scrutiny is one of the most powerful parts of the rulemaking the SEC has undertaken.</p>
<p>Moodys former compliance officer testified to the House Oversight and Reform Committee last month that Moodys did no surveillance of its muni ratings. They issued them and then left them static although they continued to bill the issuer.</p>
<p>This means that retail investors who were sold those securities had no specific or general sense of the accuracy of the rating or the pricing that derived from the rating.</p>
<p>I&#8217;m sure that once the ratings are available for analysis we will see lots of market and academic scrutiny of ratings accuracy.  Long overdue.</p>
<p>The SEC is requiring the raters to expose the histories in XBRL for more ready comparison. Here is a presentation that I gave at a conference at the FDIC last month on the topic:</p>
<p><a href="http://shopyield.com/2009/10/06/xbrl-and-credit-ratings/" rel="nofollow">http://shopyield.com/2009/10/06/xbrl-and-credit-ratings/</a></p>
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		<title>Comment on What is a Toxic Security? by Doug Wilding</title>
		<link>http://www.theratingsdebate.com/what-is-a-toxic-security/comment-page-1/#comment-76</link>
		<dc:creator>Doug Wilding</dc:creator>
		<pubDate>Thu, 22 Oct 2009 15:33:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.theratingsdebate.com/?page_id=306#comment-76</guid>
		<description>Mr. Perry-
 
You’ve asked several excellent questions.  And you hit the nail on the head regarding some of our strongest issues with the current ratings system.  The current ratings system has no way of representing the magnitude of losses on a security.  The ratings provided by the rating agencies reflect the likelihood of a bond not paying 100% of principal, but make no representation of how much principal they are projecting will be lost once that bond is determined not to pay back 100% of principal.  For example:  Are you going to lose all of your money or just 1%?  The current system does not tell us this.  This becomes a serious issue when dealing with multiple-obligor securities.  The example you provided refers to a multi-obligor security (in this case a Mortgage-Backed Security) which is comprised of a large amount of excellent borrowers who are still paying their mortgages as contracted.  Unfortunately, in your example, the rating on the bond would be downgraded to CCC or lower, even if all 900 paying borrowers continued to pay their mortgages until full payment is made. 
 
For an individual investor, the rating may not be prohibitive.  However, for banks that own this security, once it’s been downgraded to below investment grade (and possibly purchased originally with a AAA rating), the entire balance of their investment will be classified as substandard.  You read that right.  Even the “performing” portion of the security will be classified since the entire security has been rated CCC (or worse).  
 
As you might suspect, this in turn creates a much larger problem in the securitization market since many banks will not want to continue to own these securities after they have been downgraded since they will become classified as substandard (and now perceived as “toxic”).  And certainly because of the substandard classification issue, other banks are extremely hesitant to buy more of these securities.  So what we are now left with is a huge decrease in demand for these securities, and a lot of banks being forced to sell these securities because of downgrades (increasing supply in the market).  This, in a nutshell, is why prices have plummeted for mortgage securities and the secondary mortgage market is no longer functioning as it used to.
 
I hope that helps.  Your example and questions touch on the very reason we feel so strongly about the need to revamp the current ratings system.  This must happen before we can realistically expect to get the secondary mortgage market moving again, which in turn must happen before our economy truly recovers.</description>
		<content:encoded><![CDATA[<p>Mr. Perry-</p>
<p>You’ve asked several excellent questions.  And you hit the nail on the head regarding some of our strongest issues with the current ratings system.  The current ratings system has no way of representing the magnitude of losses on a security.  The ratings provided by the rating agencies reflect the likelihood of a bond not paying 100% of principal, but make no representation of how much principal they are projecting will be lost once that bond is determined not to pay back 100% of principal.  For example:  Are you going to lose all of your money or just 1%?  The current system does not tell us this.  This becomes a serious issue when dealing with multiple-obligor securities.  The example you provided refers to a multi-obligor security (in this case a Mortgage-Backed Security) which is comprised of a large amount of excellent borrowers who are still paying their mortgages as contracted.  Unfortunately, in your example, the rating on the bond would be downgraded to CCC or lower, even if all 900 paying borrowers continued to pay their mortgages until full payment is made. </p>
<p>For an individual investor, the rating may not be prohibitive.  However, for banks that own this security, once it’s been downgraded to below investment grade (and possibly purchased originally with a AAA rating), the entire balance of their investment will be classified as substandard.  You read that right.  Even the “performing” portion of the security will be classified since the entire security has been rated CCC (or worse).  </p>
<p>As you might suspect, this in turn creates a much larger problem in the securitization market since many banks will not want to continue to own these securities after they have been downgraded since they will become classified as substandard (and now perceived as “toxic”).  And certainly because of the substandard classification issue, other banks are extremely hesitant to buy more of these securities.  So what we are now left with is a huge decrease in demand for these securities, and a lot of banks being forced to sell these securities because of downgrades (increasing supply in the market).  This, in a nutshell, is why prices have plummeted for mortgage securities and the secondary mortgage market is no longer functioning as it used to.</p>
<p>I hope that helps.  Your example and questions touch on the very reason we feel so strongly about the need to revamp the current ratings system.  This must happen before we can realistically expect to get the secondary mortgage market moving again, which in turn must happen before our economy truly recovers.</p>
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