Should the Commission consider a credit rating agencys financial resources as a factor in determining NRSRO status?
No. S&P Ratings Services believes that NRSRO designation criteria focused on capitalization and resources represent an intrusion into the business operations of a credit rating agency. NRSRO status should not be conditioned on criteria based upon objective capital or resource standards. Given the broad spectrum of rating agencies of varying sizes, using independently developed expertise, ratings criteria and methodologies, it would be very difficult to define capital or resource standards appropriate for all NRSROs. Moreover, meeting a mandated level of capital or resources will not assure the credibility or reliability of an NRSRO’s rating opinions. Other Factors to Be Considered Question 20 – Should a credit rating agency that has coverage of a limited sector of the debt market or limited geographic area be eligible for designation as an NRSRO? S&P Ratings Services believes that it would be appropriate for the Commission to recognize NRSROs on a limited basis, as it has done in the p
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