SIFMA provides feedback to the Securities and Exchange Commission (SEC) in addition to SIFMA’s participation in the SEC’s Credit Ratings Agency Roundtable held in May 2013.

SIFMA recognizes the potential conflicts of interest that arise from the current issuer-pays model of credit ratings. The mere presence of a conflict of interest, however, does not imply that there will harms to parties in the transaction. Each model of the credit ratings market presented at the Roundtable, including the one envisioned in Section 15E(w), carries with it its own potential conflicts of interests, misaligned incentives, and market distortions. SIFMA believes conflicts will always exist, and must be managed.