Remember the GFC, sub-prime mortgages and so on? The following is from the summary report of issues identified in the Commission Staff's Examinations of Select Credit Rating Agencies, United States Securities and Exchange Commission (SEC): July 2008.
"None of the rating agencies examined had specific written procedures for rating RMBS and CDO. One rating agency maintained comprehensive written procedures for rating structured finance securities, but these procedures were not specifically tailored to rating RMBS and CDO. The written procedures for the two other rating agencies were not comprehensive and did not address all significant aspects of the RMBS and CDO ratings process".
"The lack of full documentation of policies and procedures made it difficult for the staff to confirm that the actual practice undertaken in individual ratings was consistent with the firm's policies and procedures. This lack of full documentation could also impede the effectiveness of internal and external auditors conducting reviews of rating agency activities".
"Rating agencies do not appear to have specific policies and procedures to identify or address errors in their models or methodologies"
Believe me, after 20 years of running a technical writing firm, working with 130 clients, we found many organisations are still, 10 years after the GFC, often exposed to the same old operational and audit risks. If this all seems a little too close to home for your firm, contact our technical writing group within Hastings Ventures https://hastings.ventures/contact-1/. We work globally.