Comment Text:
We understand that the Commission is working to develop uniform standards of credit-worthiness by engaging in consultation with the Securities and Exchange Commission, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve (FRB) and other regulators.
Further to the notice of proposed rulemaking to remove any reference to or reliance on credit ratings in Commission regulations and to propose alternatives to the use of credit ratings, please find attached the comments of The Clearing House Association L.L.C. that were submitted to the FDIC, the OCC, the FRB and the Office of Thrift Supervision on October 12, 2010, in response to their request for comments on a similar subject.
As we state in the attached letter, we propose some options and offer our analytical services to refine alternatives to credit ratings.
