In sum, as described in Section IV of this report, while the rating agencies had different policies, procedures and practices and different issues were identified among the firms examined, the Staff’s examinations revealed that:
there was a substantial increase in the number and in the complexity of RMBS and CDO deals since 2002, and some of the rating agencies appear to have struggled with the growth; significant aspects of the ratings process were not always disclosed; policies and procedures for rating RMBS and CDOs can be better documented; the rating agencies are implementing new practices with respect to the information provided to them; the rating agencies did not always document significant steps in the ratings process -- including the rationale for deviations from their models and for rating committee actions and decisions -- and they did not always document significant participants in the ratings process; the surveillance processes used by the rating agencies appear to have been less robust than the processes used for initial ratings; issues were identified in the management of conflicts of interest and improvements can be made; and the rating agencies’ internal audit processes varied significantly.