May. 19, 2022
May 19, 2022 I support removing references to credit ratings from Regulation M. Credit ratings are a vestigial artifact from a time before the information age, when doing required legwork for a decision was prohibitive. Now that information is freely available, credit ratings serve as a means to incentivize shortcut taking, undermining due diligence, and lead to suboptimal capital deployment, and to what ever extent they are relied upon, they provide a means for market manipulation.