SEC Office of Credit Ratings staff guidance: Dominion Bond Rating Service Limited

PICKARD AND DJINiS LLP
ATTORNEYS AT LAW
I9BO M STREET, N. W.
WASHINOTON, D. C. 20036
TELEPHONE
(202)223-44t8
By Hand
Mr. Michael A. Macchiaroli
Associate Director, Divison of Market Regulation Securities and Exchange Cornmission 450 Fifth Strect, N.W. Washington, DC 20549 January 21, 2003 Re: Dominion Bond Rating Service Limited Dear Mr . Macchiaroli:
We submit this letter on behalf of Dominion Bond Rating Service Limited (ttDBRS")to request assurance that the Division of Market Regulation will. not recommend enforcement action to the Commission if DBRS is considered a nationally recognized statistical rating organization ("NRSRO") for purposes of paragraphs (c)(2)(vi)(E), (F), and (M)of Rule 15~3-1under the Securities Exchange Act of 1934 (17 CFW $ 240.15~3-1). In support of this request, DBRS has supplied you and your staff with extensive information establishing that it:

1. is recognized in the United States as an issuer of credible and reliable ratings by users
   of securities ratings;
2. has adequate staffing. financial resources, and organizational structure to ensure that
   it can issue credible and reliable ratings of the debt sf issuers, including a sufficient number of qualified staff members and the ability to operate independently of economic pressures or control by the companies it rates;
3. uses systematic rating procedures that are designed to ensure credible and accurate
   ratings;
4. has access to senior-level management of issuers; and
5. has and enforces internal procedures to prevent misuse of non-public information.

Mr. Michael A. Mitcchiardi
January 21, 203
DBRS, which is registered with the Commission as an investment adviser, also has established that it has been recognized as art Approved Hating Orgnrzization by the Ontario Securities Commission. In light of the foregoing, we respectfully ask you to grant DBRS the requested relief. If you need any hrther information on this matter, please do not hesitate to contact the undersigned. Very truly yours, Mari-Anne Pisarri CC: Walter Schroeder, CFA, CMA

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PICKARD AND DJINiS LLP
ATTORNEYS AT LAW
I9BO M STREET, N. W.
WASHINOTON, D. C. 20036
TELEPHONE
(202)223-44t8
By Hand
Mr. Michael A. Macchiaroli
Associate Director, Divison of Market Regulation Securities and Exchange Cornmission 450 Fifth Strect, N.W. Washington, DC 20549 January 21, 2003 Re: Dominion Bond Rating Service Limited Dear Mr . Macchiaroli:
We submit this letter on behalf of Dominion Bond Rating Service Limited (ttDBRS")to request assurance that the Division of Market Regulation will. not recommend enforcement action to the Commission if DBRS is considered a nationally recognized statistical rating organization ("NRSRO") for purposes of paragraphs (c)(2)(vi)(E), (F), and (M)of Rule 15~3-1under the Securities Exchange Act of 1934 (17 CFW $ 240.15~3-1). In support of this request, DBRS has supplied you and your staff with extensive information establishing that it:

1. is recognized in the United States as an issuer of credible and reliable ratings by users
   of securities ratings;
2. has adequate staffing. financial resources, and organizational structure to ensure that
   it can issue credible and reliable ratings of the debt sf issuers, including a sufficient number of qualified staff members and the ability to operate independently of economic pressures or control by the companies it rates;
3. uses systematic rating procedures that are designed to ensure credible and accurate
   ratings;
4. has access to senior-level management of issuers; and
5. has and enforces internal procedures to prevent misuse of non-public information.

Mr. Michael A. Mitcchiardi
January 21, 203
DBRS, which is registered with the Commission as an investment adviser, also has established that it has been recognized as art Approved Hating Orgnrzization by the Ontario Securities Commission. In light of the foregoing, we respectfully ask you to grant DBRS the requested relief. If you need any hrther information on this matter, please do not hesitate to contact the undersigned. Very truly yours, Mari-Anne Pisarri CC: Walter Schroeder, CFA, CMA