Subject: File No. 4-661
From: Robert Kuljian

May 17, 2013

Once again a government financial regulatory agency disgraces itself by going through a faux roundtable of interested parties on rating agencies and finding that God bestows his benevolent blessing on Fitch, SP, and Moodys.

These same firms who helped our banks destroy our economy in 2007-8 by producing wildly wrong ratings for the trash that was being peddled by our TBTF banks (at great financial rewards for the rating agencies) are left, in the spirit of free markets, to compete for the prize of "most accurate ratings" and the world goes on.

We find the same nonsensical charade of arguments for not taking action. "Changing the inherent conflict of interest that comes with the issuer-pays model would create new conflicts, be costly and slow to implement, and cause uncertainty in the marketplace.

One can hardly keep from laughing at these arguments - since they are made by the same people who already destroyed our economy and markets in 2007-8.

The SEC has given them a chance to do it again and since criminality has been shown to have no consequences for the financial sector what exactly do they risk ? Do you ask the citizen to rely on the ethical standards exhibited by this industry or some market based mechanism to assure right outcomes. Fairy tales for fools.