May. 19, 2022
Dear SEC Chair Gary Gensler, SEC Commissioners, and whom else it may concern, You announced on March 23, 2022, your vote to propose changes that would remove the references to credit rating agencies from existing exceptions provided in Rule 101 and Rule 102 of Regulation M. In the Dodd-Frank Act of 2010, Congress directed federal agencies, including yours, to remove any reference to or requirement of reliance of credit ratings. You have now, twelve years later, completed your research on the matter, and only Rules 101 and 102 still have these notions, and may now be removed as well. Please proceed as soon as possible with these removals, so that no investor, on the retail or institutional level, must rely on credit ratings, which have failed us in every possible manner. My reasons being the: • 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 Thank you for the time, I remain with warm regards, Narek Khachatrian