further solidifying the entrenched position held by s&p, moody's, and fitch. a few items.ethodology disclosure. rules in the treury proposal on transparency of rin methodology could come dangerously close to meeting rating firms would have no intellectual property protection. ratings is closure requiring subscriber-based rating agencies to disclose their history of ratings and ratings actions can undermine the subscriber-based business model which is predicated on selling current and past writings to investors. treasury proposal covs all types of rating agencies, and for 100% of their ratings. requiring nrsro registration required registration of all countries issuing ratings is perhaps the most counter productive and initiative o all. not only does forcing registration run counter to the 06 act, it could create a flood of new nrsro captured by the sweeping dragnet. investors will not have the inclination to look at all of these firms and will tend to remain with the providers they know best. the big three. further, registration would impose all of the increased erect and