Conflicted agents: credit ratings, risk management and Dodd-Frank
First a safe and happy holiday to all. This week The IRA is evolving to a formal listseve for distribution. Readers of The IRA will now be able to manage their subscriptions directly. We'll also be making some changes to the landing zones for the professional and consumer web sites in coming days. Comments are always welcome. The Federal Reserve, Federal Deposit Insurance Corp and Office of the Comptroller recently held a meeting to discuss the requirements of the Dodd-Frank law to remove all references to the rating agencies from the law. The meeting hosted by Fed Governor Daniel Tarullo, FDIC Chairman Sheila Bair and acting Comptroller John Walsh, specifically focused on ANPR OCC-2010-0016 from the OCC which asks a series of questions about how to essentially replace the use of third-party ratings in the regulatory process. It seems fair to say that the Dodd-Frank legislation has created a big operational problem for regulators, who generally view the current system of quasi-monopolies that provide credit ratings to banks and other investors as adequate. As we stated in our written comments, generally speaking the rating agencies and broader analytics community have done a reasonably good job in assessing the credit risk of "plain vanilla," SEC registered corporate, municipal and RMBS/CMBS securities in the secondary market going back more than a century. Less so with banks and sovereigns where politics plays a bigger role. And obviously the excursion into the primary market for exotic subprime mortgage securitizations and CDOs was a very bad idea.