Should the Commission require periodic disclosure of performance information?
S&P Ratings Services believes that it is helpful to the market to publish its analyses as to the performance of its rating opinions. S&P Ratings Services regularly publishes default and transition studies and studies on rating trends. These studies have been provided to the Commission staff from time to time for review and are freely available to the public in hard copy and on S&P Ratings Services’ website. S&P Ratings Services’ default and transition studies contain detailed information as to the bases of its default analyses, key assumptions and methodologies, all of which demonstrate to the marketplace the performance of its credit ratings and track record. Question 52 – Should an NRSRO or issuer be required to disclose whether an issuer participated in the rating process? S&P Ratings Services believes that it is possible to perform a high quality credit analysis relying solely on publicly available information of an issuer, where, for example, the issuers are reporting companies re
