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Federal Deposit
Insurance Corporation

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FDIC and Financial Regulatory Reform

Roundtable Discussion of Alternatives to the use of Credit Ratings and Creditworthiness Standards under the Dodd-Frank Act
November 10, 2010
10:00 am - 12:00 pm

As part of the implementation of the Dodd Frank Wall Street Reform and Consumer Protection Act, the Federal Reserve Board of Governors hosted, with the FDIC and the Office of the Comptroller of the Currency, a roundtable discussion that considered alternatives to the use of credit ratings. 

The roundtable provided an open exchange of ideas and views regarding the development of creditworthiness standards as required by Section 939A of the Dodd-Frank Act, which requires all federal agencies to review and remove all references to or requirements in such regulations regarding credit ratings.  Panelists included representatives from financial institutions, banking and investor trade associations, firms that provide credit analysis (including credit rating agencies), as well as academics with expertise in credit analysis.  The roundtable discussion will supplement the public comments the agencies, including the Office of Thrift Supervision, received from the August 25, 2010, advanced notice of proposed rulemaking (ANPR) titled “Alternatives to the Use of Credit Ratings in the Risk-Based Capital Guidelines of the Federal Banking Agencies”.  The comment period on the ANPR closed October 25, 2010.

While the event was closed to the public, statements, comments and other submissions, as well as public comments on the ANPR are attached.  Discussion notes from the agencies will be made available.

Meeting Summary - PDF (PDF Help)
List of Confirmed Panelists

Public Comments on ANPR from Confirmed Panelists

American Bankers Association - PDF (PDF Help)
American Securitization Forum - PDF (PDF Help)
Independent Community Bankers of America - PDF (PDF Help)
Moody’s Analytics - PDF (PDF Help)
Moody’s Investors Service - PDF (PDF Help)
Securities Industry and Financial Markets

Public Comments and Other Submissions from Confirmed Panelists

Regulation of Rating Agencies - Edward I. Altman, et al. - PDF (PDF Help)
The Z-Metrics™ Methodology For Estimating Company Credit Ratings And Default Risk Probabilities - Edward I. Altman, et al. - PDF (PDF Help)
Institutional Risk Analytics - Christopher Whalen - PDF (PDF Help)
Comments Submitted - Joseph R. Mason, et al. - PDF (PDF Help)
Conflicts of Interest, Low-Quality Ratings, and Meaningful Reform of Credit and Corporate Governance Ratings - Charles W. Calomiris and Joseph R. Mason - PDF (PDF Help)

Last Updated 2/1/2011

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