Subject: S7-11-22: WebForm Comments from Daniel Weinstein
From: Daniel Weinstein
Affiliation: Software Engineer

May. 19, 2022

 


 May 19, 2022

 I Strongly support this change in the rule.  My reasons are:
 Antiquated manner of functioning of the rating agencies
 Overdue publications of rating updates, often delayed for obscure reasons
 Lack of consistency between the ratings
 Possible conflict of interests between issuers paying the ratings and the agencies
 Spill-over concerns to the real economy, especially in the car industry
 Unjustified impact on benchmarks, as the same players also constitute the major indices
 Benefit of due diligence and research by each investor rather than fostering blind sheep behaviors

These both Moody and especially SP have shown they have a strong bias.  Investors, advisors and institutions should be long at data not relying on outmoded ratings companies.