Since ratings are assigned by humans and humans are fallible, being more deliberate about the processes behind them can only help us. While we have made some progress in making ratings simpler and therefore more efficient, and more consistent with actual supervisory practices, I would like to see our approach to ratings made more express and deliberate.
Since the global financial crisis, the Fed, along with the other prudential supervisors, has implemented a number of controls to improve consistency and support appropriate calibration of ratings, as we view them internally. We have tools in place to monitor ratings and detect whether there is any unusual variability in them.