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	<title>Comments on: Rating Agencies Created Incentives to Issue Paper More Profitable for Them to Rate</title>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1709</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Sat, 17 Nov 2007 05:19:00 +0000</pubDate>
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		<description>I am shocked to learn that some pigs are more equal than others!</description>
		<content:encoded><![CDATA[<p>I am shocked to learn that some pigs are more equal than others!</p>
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		<title>By: brian</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1708</link>
		<dc:creator>brian</dc:creator>
		<pubDate>Sat, 17 Nov 2007 04:20:00 +0000</pubDate>
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		<description>Einhorn&#039;s comments about Basel II are particularly noteworthy.  This bank regulatory regime uses credit ratings as the basis for the entire set of reserve requirement rules for banks, and as Einhorn has demonstrated is enabling them to take imprudent risks.  It also creates a strong incentive for securitization with all of the &quot;agency&quot; problems that arise with the originate and distribute model.</description>
		<content:encoded><![CDATA[<p>Einhorn&#8217;s comments about Basel II are particularly noteworthy.  This bank regulatory regime uses credit ratings as the basis for the entire set of reserve requirement rules for banks, and as Einhorn has demonstrated is enabling them to take imprudent risks.  It also creates a strong incentive for securitization with all of the &#8220;agency&#8221; problems that arise with the originate and distribute model.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1706</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Sat, 17 Nov 2007 01:37:00 +0000</pubDate>
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		<description>Spec,&lt;br/&gt;&lt;br/&gt;Given the steadily deteriorating state of our bank balance sheets, how can anyone be confident that a conduit with voluntary bank support (I understand that some but not all conduits have fully guaranteed support) will be supported when push comes to shove.&lt;br/&gt;&lt;br/&gt;I don&#039;t see how a worse case scenario situation can work out without some of the smaller funds breaking the buck -- unless the regulators decide that money funds will get government support.  Basically I trust the regulators to be too serious about their jobs to cave in to Wall Street to that degree -- though I may definitely be wrong about that.&lt;br/&gt;&lt;br/&gt;By the way, this was not some big name firm that I could be sure would have the money to bail out it&#039;s money market fund if necessary.</description>
		<content:encoded><![CDATA[<p>Spec,</p>
<p>Given the steadily deteriorating state of our bank balance sheets, how can anyone be confident that a conduit with voluntary bank support (I understand that some but not all conduits have fully guaranteed support) will be supported when push comes to shove.</p>
<p>I don&#8217;t see how a worse case scenario situation can work out without some of the smaller funds breaking the buck &#8212; unless the regulators decide that money funds will get government support.  Basically I trust the regulators to be too serious about their jobs to cave in to Wall Street to that degree &#8212; though I may definitely be wrong about that.</p>
<p>By the way, this was not some big name firm that I could be sure would have the money to bail out it&#8217;s money market fund if necessary.</p>
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		<title>By: spec</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1704</link>
		<dc:creator>spec</dc:creator>
		<pubDate>Sat, 17 Nov 2007 01:06:00 +0000</pubDate>
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		<description>anon 1:37, &lt;br/&gt;ABCP is not a cause for concern in a money market firm.  There ia wide variety of types that are fully and partially supported. Common types are multi-seller cp with pools of assets from trade receivable, auto loans, credit cards, etc.  Typically they have some sort of liquidity or credit enhancement.  SIV&#039;s have limited enhancements and subject the investors to the market values of the securities they purchase.</description>
		<content:encoded><![CDATA[<p>anon 1:37, <br />ABCP is not a cause for concern in a money market firm.  There ia wide variety of types that are fully and partially supported. Common types are multi-seller cp with pools of assets from trade receivable, auto loans, credit cards, etc.  Typically they have some sort of liquidity or credit enhancement.  SIV&#8217;s have limited enhancements and subject the investors to the market values of the securities they purchase.</p>
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		<title>By: David Pearson</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1703</link>
		<dc:creator>David Pearson</dc:creator>
		<pubDate>Fri, 16 Nov 2007 23:26:00 +0000</pubDate>
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		<description>Yves,&lt;br/&gt;&lt;br/&gt;Greenlight Capital, Einhorn&#039;s firm, was the largest shareholder in New Century Mortgage just before its demise.  Einhorn had a seat on the company&#039;s board.  He accumulated a large portion of shares in 2006, when subprime delinquencies had already started their spike.&lt;br/&gt;&lt;br/&gt;One wonders if Einhorn blames the ratings agencies for his mistakes.&lt;br/&gt;&lt;br/&gt;Nevertheless, it was a well-written, thoughtful speech.</description>
		<content:encoded><![CDATA[<p>Yves,</p>
<p>Greenlight Capital, Einhorn&#8217;s firm, was the largest shareholder in New Century Mortgage just before its demise.  Einhorn had a seat on the company&#8217;s board.  He accumulated a large portion of shares in 2006, when subprime delinquencies had already started their spike.</p>
<p>One wonders if Einhorn blames the ratings agencies for his mistakes.</p>
<p>Nevertheless, it was a well-written, thoughtful speech.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1701</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 16 Nov 2007 18:37:00 +0000</pubDate>
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		<description>The whole problem with this stack of cards is precisely that there&#039;s way too much of &quot;mom &amp; pop&#039;s&quot; money in here.  That&#039;s what ABCP is about.&lt;br/&gt;&lt;br/&gt;I just had to kick and scream with my parent&#039;s account manager who had casually placed the proceeds of the sale of their house in a &quot;perfectly safe&quot; money market account that right now is full of ABCP and 6% SIVs.&lt;br/&gt;&lt;br/&gt;I, of course, was being completely unreasonable, since the fund only invests in AAA paper!</description>
		<content:encoded><![CDATA[<p>The whole problem with this stack of cards is precisely that there&#8217;s way too much of &#8220;mom &#038; pop&#8217;s&#8221; money in here.  That&#8217;s what ABCP is about.</p>
<p>I just had to kick and scream with my parent&#8217;s account manager who had casually placed the proceeds of the sale of their house in a &#8220;perfectly safe&#8221; money market account that right now is full of ABCP and 6% SIVs.</p>
<p>I, of course, was being completely unreasonable, since the fund only invests in AAA paper!</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1698</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 16 Nov 2007 17:57:00 +0000</pubDate>
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		<description>Einhorn&#039;s assumption about access to information is not right. &lt;br/&gt;&lt;br/&gt;New issuance investors get the same indenture, models (nobody buys without intex files), and structuring docs that the agencies get, along with most anything else they ask for. Bankers don&#039;t have the luxury to ignore requests for additional information from note buyers, and this has always been the case. Einhorn&#039;s comment may hold water for investors in the secondary markets, long after close.&lt;br/&gt;&lt;br/&gt;Again, mom &amp; pops cannot directly invest in structured products, and institutional investors have a duty to do their homework for their investors. That&#039;s why they get paid the big bucks. &lt;br/&gt;&lt;br/&gt;Just because you&#039;re legally allowed to smoke doesn&#039;t mean that you should. People shouldn&#039;t shed tears for big boys who lose money on their bets. They sure didn&#039;t complain when they made great returns during the boom years.</description>
		<content:encoded><![CDATA[<p>Einhorn&#8217;s assumption about access to information is not right. </p>
<p>New issuance investors get the same indenture, models (nobody buys without intex files), and structuring docs that the agencies get, along with most anything else they ask for. Bankers don&#8217;t have the luxury to ignore requests for additional information from note buyers, and this has always been the case. Einhorn&#8217;s comment may hold water for investors in the secondary markets, long after close.</p>
<p>Again, mom &#038; pops cannot directly invest in structured products, and institutional investors have a duty to do their homework for their investors. That&#8217;s why they get paid the big bucks. </p>
<p>Just because you&#8217;re legally allowed to smoke doesn&#8217;t mean that you should. People shouldn&#8217;t shed tears for big boys who lose money on their bets. They sure didn&#8217;t complain when they made great returns during the boom years.</p>
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		<title>By: john c, halasz</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1694</link>
		<dc:creator>john c, halasz</dc:creator>
		<pubDate>Fri, 16 Nov 2007 15:01:00 +0000</pubDate>
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		<description>&quot;the rating agencies say they shouldn&#039;t be held accountable for their opinions because they are.....nothing more than journalists engaged in free speech.&quot;&lt;br/&gt;&lt;br/&gt;So rating agencies are not different from tout sheets at the race track?</description>
		<content:encoded><![CDATA[<p>&#8220;the rating agencies say they shouldn&#8217;t be held accountable for their opinions because they are&#8230;..nothing more than journalists engaged in free speech.&#8221;</p>
<p>So rating agencies are not different from tout sheets at the race track?</p>
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		<title>By: Bernard</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1693</link>
		<dc:creator>Bernard</dc:creator>
		<pubDate>Fri, 16 Nov 2007 14:18:00 +0000</pubDate>
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		<description>Einhorn&#039;s commentary on the credit rating agencies was brilliant. Their integrity is thoroughly compromised.  &lt;br/&gt;&lt;br/&gt;Take MBS paper and wrap it with a CDO, and guess what?  Overall, it gets a higher credit rating!&lt;br/&gt;&lt;br/&gt;That was a big reason to pump out all those CDOs---the issuers make more money with a higher credit rating.&lt;br/&gt;&lt;br/&gt;And this rigged structure of different credit rating standards for different products played right into the hands of the credit rating agencies---as it was undoubtedly intended by them.  &lt;br/&gt;&lt;br/&gt;For they make FAR higher profit margin on rating CDOs than all the other plain-vanilla products. &lt;br/&gt;&lt;br/&gt;Everyone must read that commentary.  It was very educational.</description>
		<content:encoded><![CDATA[<p>Einhorn&#8217;s commentary on the credit rating agencies was brilliant. Their integrity is thoroughly compromised.  </p>
<p>Take MBS paper and wrap it with a CDO, and guess what?  Overall, it gets a higher credit rating!</p>
<p>That was a big reason to pump out all those CDOs&#8212;the issuers make more money with a higher credit rating.</p>
<p>And this rigged structure of different credit rating standards for different products played right into the hands of the credit rating agencies&#8212;as it was undoubtedly intended by them.  </p>
<p>For they make FAR higher profit margin on rating CDOs than all the other plain-vanilla products. </p>
<p>Everyone must read that commentary.  It was very educational.</p>
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		<title>By: Independent Accountant</title>
		<link>http://www.nakedcapitalism.com/2007/11/rating-agencies-created-incentives-to.html#comment-1692</link>
		<dc:creator>Independent Accountant</dc:creator>
		<pubDate>Fri, 16 Nov 2007 14:11:00 +0000</pubDate>
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		<description>I am a CPA and have been saying these things about the rating agencies since 1999 when &quot;Bowie Bonds&quot; were created.  The rating agencies, like the Big 87654 CPA firms are in similar businesses and are similarly compromised.</description>
		<content:encoded><![CDATA[<p>I am a CPA and have been saying these things about the rating agencies since 1999 when &#8220;Bowie Bonds&#8221; were created.  The rating agencies, like the Big 87654 CPA firms are in similar businesses and are similarly compromised.</p>
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