Click here to view AFR’s comment letter to the SEC  regarding the study on assigned credit ratings for structured finance products mandated by section 939F (Franken Amendment) of Dodd-Frank.  We said it is vitally important that the Commission explore more sweeping reforms designed to directly address the conflicts of interest at the heart of the rating agency business model, as well as the deficiencies in professional standards that have emerged from the ratings agencies incentives to gain business from the issuers who pay them.