May. 19, 2022
Dear SEC, Please consider that investment firms, financial advisors, financial planners, and other financial institutions making investment decisions should be required to do maximum due diligence and use critical thinking in their analysis, and not overly rely on credit rating agencies. Over-reliance on credit ratings agencies, and the associated over-reliance on index fund investing created by the same agencies, makes the market less efficient, less robust, and more volatile. The incentives to rely only or primarily on credit ratings for investment decisions leads to gross mis-allocation of capital, and large money managers relying on very mediocre and non-representative metrics. If these arguments are sound and convincing, please consider removing the requirement of certain financial investment decision makers to rely on credit ratings, and the imperfect credit ratings agencies. Sincerely, Cameron Beebe