Evaluator Bench
Assurance regime; jurisdiction US/EU

Credit rating agencies

A payer-conflicted assurance market that regulators chose to license and supervise rather than restructure. Outcomes in 2008 show the limits of disclosure and licensing without liability or competition.

Path signature

V voluntary D delegation T trigger O oversight T trigger I independence

Similarity of its opening to frontier AI: 0.44 (matched opening VDTOTI)

Stages reached

Voluntary1909
Trigger1970
Mandatenot reached
Standardsnot reached
Oversight1975
Independence2010
Accessnot reached

Mechanisms

Before reformNow
paysOA
selectsOA
accessshallowdeep
publishespublicpublic
overseesnoneregulator

Investor-pays until 1970; issuer-pays since, with SEC oversight after 2006 and 2010.

Payer, access, publication

Who pays. Issuer pays since the 1970s; investor-pays subscription model before that.
Access. Non-public issuer information under confidentiality (Regulation FD exemption).
Publication. Ratings public; methodologies disclosed by regulation after 2010.

Milestones

YearKindEventStrengthHarm
1909voluntary assuranceMoody's publishes the first bond ratings, sold to investors by subscription.source
1970delegationIssuer-pays model makes the rated party the client.source
1970triggerPenn Central default; agencies begin charging issuers rather than investors.financial_loss: Largest US bankruptcy to datesource
1975accreditationSEC creates the NRSRO designation, embedding ratings in regulation.2source
2006accreditationCredit Rating Agency Reform Act formalizes NRSRO registration and SEC oversight.3source
2008triggerStructured-finance ratings fail in the financial crisis.financial_loss: Systemic losses far above $1Bsource
2010independence ruleDodd-Frank Title IX: SEC Office of Credit Ratings, methodology disclosure, analyst separation from sales, expanded liability exposure.3source

seed; secondary sources; verify each milestone against a primary source before citing in the paper Data: data/industries/credit-ratings.json