Monday, August 22, 2011

Deven Sharma to step down as S&P president

http://xfinity.comcast.net/articles/news-general/20110823/NEWS-US-SP-PRESIDENT/
Excerpt:

Deven Sharma to step down as S&P president

36 minutes ago
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(Reuters) - Deven Sharma will step down as president of ratings agency Standard & Poor's to work on the company's strategic portfolio review before leaving the company at the end of the year.
Sharma will be replaced as president of the ratings agency by Douglas Peterson, chief operating officer of Citibank effective September 12, S&P's parent company McGraw-Hill Companies Inc said in a statement.
The company said it began a search for a new president for S&P after the company split S&P into two separate organizations at the end of last year.
The Financial Times, which first reported news of Sharma's resignation, said his resignation is not related to S&P's downgrade of the United States' credit rating or reports that the agency is being probed by the U.S. Justice Department in connection with its ratings of mortgage securities.
S&P has been under fire from lawmakers, market players and the U.S. Treasury Department since its decision to cut the U.S. credit rating earlier this month, and just last week, news emerged that the Justice Department is investigating the firm over its actions on mortgages leading up to the financial crisis.
The board of McGraw-Hill Companies made the decision to replace Sharma at a meeting where it also discussed its ongoing strategic review on Monday, the Financial Times said.
McGraw-Hill directors and executives met on Monday with Jana Partners LLC, a hedge fund, and the Ontario Teacher's Pension Fund to hear their arguments that the company should be broken up.
(Reporting by Abhishek Takle in Bangalore; Editing by Gary Hill)

http://en.wikipedia.org/wiki/Deven_Sharma
Excerpt:
Sharma worked with manufacturing companies, Dresser Industries and Anderson Strathclyde. After that he joined Booz Allen Hamilton where he worked for 14 years and led its strategy, operations performance, sales and marketing, and global expansion engagements for service-, marketing- and information-intensive companies. He left the company as a partner and joined McGraw-Hill in 2002. He served as Executive Vice President of Global Strategy of McGraw-Hill Companies Inc., from January 15, 2002 to October 2006 and as Executive Vice President of Investment Services and Global Sales of Standard & Poor's, from November 1, 2006. He was named president of Standard & Poor's in August 2007.
Sharma serves on the boards of CRISIL, The US-China Business Council[4] and Asia Society Business Council. He served as a Director of 1-800-Flowers.com Inc. from May 12, 2005 to March 16, 2007. He has authored three publications: The Truth About Customer Solutions, Customer Solutions-Pilots to Profits, and Connecting the Demand Chain.

Anderson Strathclyde part 1
http://www.youtube.com/watch?v=zC59f5JI9ns

http://cfrwebnet.wordpress.com/2011/06/14/shafer-to-shenk-2/
Excerpt:
Deven Sharma
B. 1956. … is the President of Standard & Poor’s, a Division of The McGraw-Hill Companies and the world’s foremost source of [bogus and misleading] financial market intelligence. Standard & Poor’s President (2007-); Standard & Poor’s EVP Investment Services and Global Sales (2006-07); McGraw-Hill EVP Global Strategy (2002-06); Booz Allen Hamilton Partner; Dresser Industries; Anderson Strathclyde; Member of the Board of 1-800-Flowers.com Inc. (2005-07); Member of the Board of Crisil Ltd (2005-); Asia SocietyUS-China Business Council Board of Directors.
-?>Deven Sharma 29 Harkim Rd; Greenwich, CT 06831-3623 (203) 531-1147 [55-59 / Anjali B Sharma, Naina Sharma]
-Deven Sharma Croton On Hudson, NY 10520 Send email


http://www.sourcewatch.org/index.php?title=Longwall_mining
Excerpt:
Longwall mining, a form of underground mining designed to completely remove underground coal seams, results in land subsidence over large areas. As documented by reports describing subsidence impacts in Pennsylvania and elsewhere, longwall mining produces serious impacts to buildings, surface water supplies, aquifers.[11] In 2009, longwall mining accounted for 166.4 million tons of coal, or 50% of U.S. underground coal production. This included 101.2 million tons in Appalachia, 12.2 million tons in the Illinois basin, and 53.1 million tons in the West.[12] According to the Energy Information Administration, longwall mine seam heights average 71 inches in Appalachia, 86 inches in the Illinois Basin, and 127 inches in the West.[13] Assuming 1800 tons of recoverable coal per acre foot, the amount of surface area affected by longwall mining in 2009 was 13,235 acres.

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Here is the letter that Mr. Devon Sharma wrote to the United States S.E.C. As the New York Times indicated, Mr. Sharma thinks credit rating agencies should have privacy regarding the errors they make. Also, he does not think it is appropriate for an agency like the S.E.C. to create a “definition” of what might constitute a glaring “error” in calculating the creditworthiness of a country, or state, or city, or corporation.



August 8, 2011
Ms. Elizabeth Murphy, Secretary
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090
Re: Proposed Rules for Nationally Recognized Statistical
Securities Exchange Act of 1934 - Rel. No. 34-64514;
File No. S7-18-11 (May 18, 2011)
Dear Ms. Murphy:
Standard & Poor’s Ratings Services ("Ratings Services"), a nationally recognized statistical rating organization ("NRSRO") registered under Section 15E of the Securities Exchange Act of 1934 (as amended, the "Exchange Act"), welcomes the opportunity to provide the Commission with its views on matters addressed in the release referenced above (the "Release"). In the Release, the Commission seeks comment on a number of proposals designed to fulfill statutory mandates in various provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). Following a summary of our views, we respond to questions raised by the Commission. For ease of reference, we have followed the subject matter order in Part II of the Release, using the same section designations, and adopted a numbering system for the questions within each section and subsection.
.
I. Executive Summary
Ratings Services supports the goals of the Dodd-Frank Act, and of the Commission, to enhance investor understanding of credit ratings and the ratings process and to increase the overall transparency of that process. Over the past several years, the Commission has engaged in extensive rulemaking to further these goals. Ratings Services has also taken many steps to meet these goals, including enhancing our governance and control framework, updating criteria, instituting a more rigorous analyst training and testing education program, and expanding our efforts to explain the role of ratings to market participants. While many of the Commission’s proposals in the Release will advance the legislative and regulatory goals, we do have concerns with a number of the Commission’s proposals. These concerns fall into four major areas—analytical independence, usefulness to the public, effect on competition and international consistency.
President
New York, NY 10041
212-438-5600 Tel
212-438-0200Fax
deven_sharma@standardandpoors.com
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A. Analytical Independence
A cornerstone of our and other NRSROs’ business has always been the importance of analytical independence. This was recognized by Congress in drafting the Credit Rating Agency Reform Act of 2006 (the "Reform Act"). Section 15E(c)(2) of the Exchange Act (added pursuant to the Reform Act) prohibits the Commission from regulating the substance of credit ratings and the procedures and methodologies by which NRSROs determine credit ratings. Nothing in the Dodd-Frank Act changes this restriction. We are concerned that some of the proposed rules have the potential to regulate the substance of credit ratings and compromise analytical independence.
For example, if the Commission were to define the term "significant error," as it suggests in Section II.F, we believe it would effectively be substituting its judgment for that of the NRSRO, thereby regulating the substance of credit ratings. Because credit ratings reflect the subjective opinions of committees of rating analysts and incorporate both quantitative and qualitative factors, we believe it would be difficult, if not impossible, for the Commission to establish a principled definition of what might constitute a "significant error." In this case and many others throughout the Release, we express our concern with seeking to create objective standards where the nature of the business does not readily lend itself to such objectivity or a "one-size-fits-all" approach. Rather, as a general matter, we believe that giving NRSROs the freedom to determine the significance of issues on a case-by-case basis in light of the factors relating to each situation and applying each NRSRO’s methodologies, is more appropriate and consistent with maintaining analytical independence than imposing external standards that will be inconsistent with the subjective and multifaceted nature of the analytical process.
Similarly, we understand that proposed Rule 17g-8(c)(1) would require an NRSRO to take a credit rating action - placing a credit rating on credit watch or review - immediately upon determining that a credit rating analyst who participated in rating an entity or its securities has taken a job with that entity. Because a credit watch designation is an analytical action, this requirement would encroach on NRSROs’ analytical independence. Indeed, Ratings Services would be required to place a rating on credit watch even if our analysts determine that the potential conflict would not actually affect the rating in question. We urge the Commission to clarify how this proposed rule is intended to operate and avoid an outcome that would impair analytical independence.
In addition, elements of the proposed rules effectively seek to transform credit ratings from being a measure of relative ranking to one of absolute ranking, in contravention of Section 15E(c)(2). Our credit ratings do not connote a particular expectation of the probability of default or the amount of
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