During the past 30 years, regulators, including the Commission, have increasingly used credit ratings to help monitor the risk of investments held by regulated entities, and to provide an appropriate disclosure framework for securities of differing risks. Since 1975, the Commission has relied on ratings by market-recognized credible rating agencies for distinguishing among grades of creditworthiness in various regulations under the federal securities laws. These “nationally recognized statistical rating organizations,” or “NRSROs,” are recognized as such by Commission staff through the no-action letter process. There currently are three NRSROs – Moody’s Investors Service, Inc. (“Moody’s”), Fitch,.
