February 7, 2011
Securities and Exchange Commission
via email to rule-comments@sec.gov
Re: Comments on File Number 4-622: Credit Rating
Standardization Study
To Whom It May Concern:
A.M. Best Company ("A.M. Best") appreciates the opportunity to comment on the proposed study by the Securities and Exchange Commission ("SEC") regarding credit rating standardization. It is our hope that the standardization study will reflect the diversity in the credit rating industry, and the differences between the sizes of the various credit rating agencies ("CRAs") and the products they rate. In the end, any standardization effort should allow for the CRA industry to continue to effectively serve specialized credit ratings markets, such as ratings of insurance companies.
A.M. Best, a smaller NRSRO headquartered in Oldwick, New Jersey, has built a strong reputation worldwide primarily based on rating the financial strength of insurance companies. During the over hundred-year history of A.M. Best, our company has grown from employing a handful of workers in 1899 to over 500 highly-skilled employees working today in our Oldwick headquarters. Consumers, investors and others come to us for information and insight into the insurance industry and individual companies operating in this segment. The overwhelming majority of our ratings are primarily based on audited financial information provided by the companies that we rate.
The characteristics of A.M. Best demonstrate the difficulty inherent in any effort to standardize CRA terminology or procedures. A.M. Best primarily focuses on rating entities and products that differ from the structured product ratings that are likely to be the focus of the study. A.M. best also uses quality control and rating surveillance procedures that are unique and important to our customers. As such, A.M. Best is concerned about any effort to standardize terminology that would compromise the unique aspects of A.M. Best's business model.
A failure to account for the vast differences between ratings of predictable and traditional entities such as insurance companies and the ratings of complex, and inherently more opaque, structured financial products could ultimately undermine the SEC's effort to increase the transparency and quality of credit ratings. If standardization is implemented based solely upon the ratings procedures utilized by the small number of companies that dominate the structured products market, then it will make it more difficult for companies such as A.M. Best to effectively serve their customers. Standardized terminology may preclude A.M. Best from providing the type of detailed and informative surveillance and reports that have served the insurance industry well for the past century.
Our specific concerns will depend on the actual standardization proposals, and whether the proposed study fully investigates, and accounts for, the differences between CRAs and the products and entities they rate. Accordingly, A.M. Best is available to SEC to discuss these issues during the course of the study, and looks forward to commenting on any standardization proposals when they become available.
Very truly yours,
A.M. Best Company