The Unpublished Grade: How Private Letter Ratings Came to Certify Insurers’ Trillion-Dollar Private Credit Expansion—and What Institutional Investors Must Demand Before They Trust the Next Investment-Grade Label

In June 2024, the Capital Markets Bureau of the National Association of Insurance Commissioners—the standard-setting body behind state insurance regulation in the United States—published a special report on the private ratings spreading through American insurers’ bond portfolios. Its analysts had examined 109 private credit securities that the NAIC’s own Securities Valuation Office had previously assessed and that later received confidential ratings from commercial rating agencies. The comparison produced one of the most lopsided data sets a financial regulator has published in years: 106 of the 109 securities, roughly 97 percent, carried a private rating higher than the SVO’s original assessment.¹ Of the securities rated higher, thirty-eight—36 percent—were more than three notches above the regulator’s view. Eight sat six or more notches higher, the distance separating a speculative single-B credit from an investment-grade triple-B, and every one of those eight ratings had been issued by a smaller rating agency.¹

Within a year, the report was gone. In May 2025, the NAIC pulled it from its website,² and Bloomberg reported that the retraction followed pushback from the industry.³ The stated explanation was that the report needed “to undergo further editorial work.”³ No revised version has been published since.³

A regulator’s study documenting systematic ratings inflation, withdrawn under industry pressure, would be a governance story in any corner of the capital markets. In this corner, it is a solvency story. According to AM Best data, United States life and annuity insurers hold approximately $6 trillion of invested assets, of which roughly $1 trillion is allocated to private credit—and a little less than half of that debt, approximately $419 billion, is graded by ratings the investing public will never see.⁴ These are “private letter ratings”: credit opinions delivered in a confidential letter, disclosed only to the issuer that commissioned them and a limited set of investors, and insulated from the market scrutiny that disciplines every published grade.⁵ They have quietly become the load-bearing wall of the insurance industry’s private credit expansion. New research from Columbia Business School, examined below, finds that privately rated bond holdings at United States life insurers grew from $46 billion in 2018 to $481 billion by 2025—a roughly tenfold increase in seven years, rising from 1.5 percent to 12.2 percent of the sector’s bond portfolios.⁶ S&P Global Market Intelligence, measuring at fair value, counted more than $408 billion of private letter rated bonds at life insurers as of September 30, 2025, and found that such securities accounted for nearly one of every ten dollars of bonds the sector acquired in the third quarter of 2025 alone.⁷

Buxton Helmsley has devoted much of its recent research to the quiet degradation of the market’s independent verification functions: the auditors whose ownership now answers to private equity,⁸ the activist short sellers who have withdrawn from fraud detection,⁹ the private credit marks that no market ever tests,¹⁰ and the insurance balance sheets that private capital managers have converted into permanent funding engines.¹¹ This article addresses the gatekeeper that series has yet to examine—the credit rating agency—at the precise point where its work has migrated beyond the reach of every mechanism that once kept it honest.

The Machinery Nobody Sees

State insurance regulation ties an insurer’s required capital directly to the credit quality of its investments. Every bond an insurer holds receives an NAIC designation—historically a scale of one through six, expanded in 2021 into twenty granular categories that track the familiar rating-agency scale nearly notch for notch—and each designation carries a risk-based capital charge determining how much capital the insurer must hold against the position.¹² The 2021 reform made the scale steep: the charge on a triple-A bond fell by more than half, the charge on a bond rated A-minus rose by 162 percent, and charges continue climbing sharply as ratings descend toward and below the investment-grade boundary.¹² Under this architecture, a rating functions as a price. Each notch either releases or consumes regulatory capital, and capital is the scarcest input in the insurance business model.

The second piece of machinery is the filing exemption. Securities carrying a rating from an SEC-registered rating agency—a nationally recognized statistical rating organization, or NRSRO—are generally exempt from independent analysis by the Securities Valuation Office; the commercial rating converts, more or less automatically, into the NAIC designation that sets the capital charge.¹³ The exemption was built for public bond markets, where a published rating faces continuous adversarial testing from prices, analysts, journalists, and competing agencies, and where a grade that diverges too far from observable reality embarrasses its author in front of the entire market.

A private letter rating short-circuits both premises at once. In the public markets, a rating is an opinion issued into a crowd of critics, every one of them positioned to profit from proving it wrong. A private letter rating enters a vault. It is unpublished; it generates no surveillance commentary the market can read; no bond price visibly reprices against it; and, in the overwhelming majority of cases, no second opinion exists—the Columbia researchers found that only 1.7 to 3.4 percent of privately rated bonds held by any insurer in a given year carry a contemporaneous public rating at all.⁶ The rating still sets the capital charge. It simply does so unseen.

Three Firms, Twenty Analysts, Eighty-Six Percent

The composition of the firms issuing these grades deserves as much attention as the grades themselves. In the public markets, S&P Global, Moody’s, and Fitch account for roughly 95 percent of all outstanding NRSRO ratings.⁶ The private letter market inverted that structure. By the end of 2023, smaller agencies—Egan-Jones Ratings, Kroll Bond Rating Agency, and Morningstar DBRS among them—accounted for nearly 86 percent of United States insurers’ private letter rated exposure, up from roughly 69 percent at the end of 2019.¹ The International Monetary Fund observed the same migration from the other direction: the three largest agencies rated approximately 1,000 private securities in 2023, essentially unchanged from 2019, while specialized firms rated roughly 7,000, up from about 2,000 four years earlier.¹⁴ The growth in this market has concentrated among the agencies willing to rate what the incumbents would not, at speeds and prices the incumbents would not match.

The scale-versus-staffing arithmetic at the market leader illustrates the concern. Bloomberg reported in June 2025 that Egan-Jones—a firm describing itself as the market’s most prolific grader of private credit—had rated more than 3,000 private credit investments in 2024 alone with a staff of roughly 20 analysts.¹⁵ The Wall Street Journal, examining the same market, reported that conflicts of interest embedded in issuer-paid private ratings were fueling investor concern.¹⁶ In July 2025, Senator Elizabeth Warren wrote to eight rating agencies active in the market—Egan-Jones among them—demanding answers about their private credit ratings practices and their management of conflicts of interest, citing, among other reporting, the findings of the withdrawn NAIC analysis.¹⁷ In November 2025, Bloomberg reported that the SEC had been scrutinizing Egan-Jones’s ratings practices in an ongoing probe—one that, as of that reporting, had produced no accusation of wrongdoing.¹⁸ The history preceding that probe is worth recalling. In January 2013, Egan-Jones and its founder settled SEC charges—without admitting or denying the findings—that the firm had made willful and material misstatements in its NRSRO registration application, accepting bars of at least eighteen months from rating asset-backed and government securities issuers in that capacity.¹⁹ In March 2026, the SEC ordered a formal review of the firm’s application to resume rating those very categories.²⁰

Fairness requires the counterarguments, and there are two serious ones. The first is structural: private placements have existed for decades, insurers have long originated them, and smaller agencies specialized in a market segment the majors neglected—so their growth, the industry argues, reflects genuine demand for specialized coverage.²¹ The second is empirical, and Fitch has advanced it most rigorously with respect to its own book: Fitch reports that its private ratings are assigned under the same criteria, committee processes, and surveillance as its public ratings, and that they exhibit similar long-term default rates.¹ Both points deserve weight. Neither, however, engages the aggregate evidence, which concerns how the private rating channel performs across the entire market—well beyond the practices of any single agency.

One Hundred Nine Securities—Then Four Trillion Dollars

The withdrawn NAIC analysis was vulnerable to a fair methodological criticism: 109 securities is a small sample. Its internal patterns, however, were difficult to dismiss. Private letter ratings from the smaller agencies averaged three notches above the SVO’s assessments; even the largest agencies’ private ratings averaged two notches above, though none reached six.¹ A separate review carried out by the SVO in 2023 found that 7 percent of sampled private letter ratings deviated from the SVO’s initial designation by six or more notches—two full rating categories.¹ When the NAIC withdrew the report rather than expand it, the question it raised did not disappear. It waited for someone with better data.

The answer arrived in a working paper dated May 31, 2026, from three Columbia Business School researchers—Xuelin Li, Sangmin Oh, and Giacomo Ricciardi. “Rating Without Market Discipline” examined regulatory filings covering 650 United States life insurers from 2018 through 2025: more than 2.8 million bond-insurer-year observations spanning over $4 trillion in assets.³ ⁶ Because NAIC Schedule D filings disclose the channel through which each bond’s rating was obtained—public rating, private letter, or the SVO’s own assessment—the researchers could compare bonds carrying identical grades certified through different doors. The findings compound one another. When bonds migrated from the SVO’s in-house channel into the private rating channel, they were upgraded more than four times as often as they were downgraded; when comparable bonds migrated to public ratings instead, upgrades and downgrades occurred at roughly equal rates.⁶ Conditional on carrying the same rating, privately rated bonds were approximately twice as likely to become impaired within one year as their publicly rated equivalents, with the gap widening at the two-year horizon.⁶ Within the same issuer—the tightest comparison available—privately rated high-yield bonds showed excess impairment rates of four to seven percentage points relative to publicly rated bonds of the very same company.⁶ The authors’ calibration suggests private ratings understate risk by roughly 2.5 to 3.3 notches, and that applying even a conservative two-notch correction would have raised required capital on insurers’ bond holdings by an average of $4.5 billion per year from 2021 through 2025—a cumulative five-year shortfall of $22.6 billion.⁶

The timing of the growth supplies its own evidence. Exploiting the NAIC’s 2021 move to twenty granular capital categories—a reform that mechanically raised charges on many holdings—the researchers document behavior consistent with insurers strategically routing bonds through the private channel for capital relief precisely when capital became more expensive.⁶ Nor is the exposure evenly distributed. Fitch’s analysis of the NAIC data found that insurers affiliated with private equity or alternative asset managers held private letter rated securities at well over twice the industry’s average concentration—17 percent of bonds at the end of 2023, against roughly 7 percent for United States insurers overall—and press accounts of the Columbia study note that growth has been most pronounced at insurers affiliated with the largest alternative managers.¹ ²² Readers of Buxton Helmsley’s prior work on the private-capital annuity complex will recognize the balance sheets in question.¹¹

Intellectual honesty requires two caveats. The Columbia paper is a working paper that has not completed peer review. And it has drawn a substantive rebuttal: Kroll Bond Rating Agency published a response arguing that the paper’s headline conclusions rest on assumptions extending beyond the directly observed data, and that its strongest evidence points to “pockets of regulatory sensitivity” rather than systemic undercapitalization.²³ Institutional readers should weigh that rebuttal seriously—while noting who wrote it. KBRA is one of the three firms that dominate the market under examination. When the referee’s findings are contested chiefly by the players they penalized, the appropriate response is more independent testing, on data no participant controls.

The Arithmetic of a Notch

Why would inflation of this particular kind pay so well? Fitch quantified the stakes with uncomfortable precision. Taking a single-B credit—the average rating in its own private mid-market corporate portfolio—and lifting it six notches to triple-B would cut the pre-tax risk-based capital charge for a life insurer by approximately 84 percent, before diversification adjustments.¹ Eight securities in the NAIC’s withdrawn sample received uplift of at least that magnitude.¹ A six-notch difference of professional opinion, delivered confidentially, converts a speculative loan into an investment-grade holding and releases the overwhelming majority of the capital a regulator would otherwise require against it.

The framework then compounds the incentive, because a single rating suffices. The NAIC’s own Securities Valuation Office saw this coming years before the boom. In a February 2020 issue paper, the SVO flagged reliance on a single private letter rating as a red flag and recommended that at least two independent ratings be required for any designation derived from commercial ratings—with the lower of the two applied.¹ The recommendation was never formally adopted. The result is a market in which the economically rational behavior for an issuer—or for an insurer’s affiliated asset manager assembling product for its own balance sheet—is to solicit indicative views and engage the agency prepared to deliver the highest grade, knowing the grade will never be published, never be marked against a market price, and, in more than 96 percent of cases, never be compared against a public rating of the same security.⁶ Financial economists long ago named the equilibrium that emerges when raters compete for issuer fees under such conditions: ratings shopping. It is precisely the incentive the NAIC has said it fears, and the reason its analysts went looking in the first place.¹

An Echo the Market Has Heard Before

The United States has run this experiment. In the years before 2008, issuer-paid rating agencies competed for fees to grade opaque structured products, and regulated institutions held capital against those products in proportion to the purchased grade. The Financial Crisis Inquiry Commission’s verdict on the arrangement was unsparing, concluding that the failures of the credit rating agencies were “essential cogs in the wheel of financial destruction.”²⁴ Congress responded, in part, through Section 939A of the Dodd-Frank Act, ordering every federal financial regulator to strip references to credit ratings out of its rules, on the theory that hardwiring capital requirements to purchased opinions had proven catastrophic.²⁵

That reform never reached insurance. State insurance regulation sits outside the federal framework Section 939A amended, and the NAIC’s filing-exemption machinery has continued converting commercial ratings directly into capital requirements—even as the instruments being rated migrated from public bond markets, where a bad grade embarrasses its author, into private markets, where a generous grade is invisible. Every structural condition the FCIC identified is present in the private letter rating market: issuer selection and payment, capital rules keyed to the resulting grade, and competition among raters for the mandate. Joining them is a condition the mortgage machine never enjoyed—secrecy. The triple-A ratings of 2007 were at least published, so their collapse was observable in real time. A private letter rating can be wrong for years inside a filing cabinet. And what sits behind these grades this time is the general-account portfolio backing life insurance policies and retirement annuities: promises measured in decades, made to households who will never learn which rating channel certified the assets behind them.

The Regulator Reaches for the Ratings—Slowly

The NAIC has not been idle, and its recent reforms deserve acknowledgment. Since January 1, 2022, insurers have been required to file the rationale reports behind private letter ratings with the SVO,²⁶ and the deadline has since tightened to within 90 days of a rating action, with an expectation of genuine analytical substance.²⁷ The NAIC has moved collateralized loan obligations out of the filing-exempt category entirely, developing its own modeling rather than accepting commercial ratings for capital purposes.²⁷ A due-diligence framework governing the use of credit rating providers is under construction,²⁷ and Bloomberg reports that the NAIC is developing a process to test the appropriateness of ratings, with the possibility of barring firms exhibiting persistent problems.³ Most significantly, the “Discretion Amendment” took effect on January 1, 2026: the SVO may now challenge any filing-exempt rating that differs from its own assessment by three or more notches, and if the challenge is upheld, the capital charge will be based on the SVO’s designation or a substituted rating from another agency.¹ ⁴

The limits of these reforms deserve equal billing. The Discretion Amendment was significantly narrowed from its original proposal after industry consultation; it carries procedural rights allowing insurers and rating firms to contest challenges; policy analysts tracking the process expect it to be used rarely; and the systems required to operationalize it were still being built as it took effect.⁴ More fundamentally, its three-notch threshold means a systematic inflation of two and a half notches—the very magnitude the Columbia study measures—passes through untouched. The researchers’ conclusion on this point should concentrate minds: the regulator’s internal assessments are more conservative than commercial private ratings, its analytical capacity is constrained, and the disclosure reforms adopted to date have not closed the gap.⁶ The Treasury Department has expressed renewed interest in insurers’ private credit exposure,⁴ and the International Monetary Fund has warned that keeping the risk of inflated ratings to a minimum requires ensuring that private rating assessments are sound.¹⁴ Warnings, however, are not capital. Between the regulator’s reach and the market’s practice sits a gap that only disclosure—and the institutions demanding it—can close.

What Institutional Investors Must Demand

For investors in publicly traded insurers, and in the alternative asset managers that own insurance balance sheets, the first demand is disclosure of concentration: what share of the general account carries private letter ratings; which agencies issued them; how much of the portfolio’s investment-grade designation rests on a single private rating from a single smaller agency; and how those figures have moved year over year. An insurer whose reported capital adequacy depends materially on unpublished grades from firms rating thousands of deals with a few dozen analysts is carrying a risk no current line item captures, and management teams should be made to quantify it on earnings calls and in investor meetings—well before it surfaces in statutory filings that few public-market analysts read.

Second, investors must demand verification economics mirroring what the SVO itself recommended in 2020: a second, independent rating—or a contemporaneous public benchmark—on material private credit positions, with the more conservative grade governing internal risk assessment even where regulation does not require it. A management team that resists a second opinion on a nine-figure position has told investors something important about what it expects the second opinion to say.

Third, demand impairment history by rating channel. The Columbia study demonstrates that this analysis is possible using regulatory data alone; any insurer can perform it on its own portfolio in a matter of days. If privately rated holdings are impairing at rates consistent with their assigned grades, the disclosure costs the insurer nothing. If they are impairing at the rates the academic evidence suggests—roughly twice the rate of identically rated public bonds—investors are entitled to know before the credit cycle turns.⁶

Fourth, demand related-party look-through. Where an insurer’s assets are originated by an affiliated asset manager, investors must ask who selects and pays the rating agency for those assets, whether indicative ratings were solicited from multiple agencies before the mandate was awarded, and whether any purchased asset was previously declined a rating elsewhere. The intersection of affiliated origination and private ratings is where every incentive described in this article compounds.¹¹

Fifth, for limited partners and allocators: rated-note feeder structures and similar insurance-oriented vehicles should prompt the question of what the rating is actually for. A rating that exists primarily to reduce a counterparty’s capital charge, issued privately by an agency selected for that purpose, is a regulatory artifact—and underwriting should treat it accordingly. Allocators should likewise ask their private credit managers whether fund assets carry private ratings, from whom, and what those ratings imply about the marks, a question that connects directly to the valuation architecture Buxton Helmsley has examined previously.¹⁰

Finally, institutional investors should lend their weight to transparency at the system level: republication of the withdrawn NAIC analysis in updated and methodologically hardened form; annual publication of aggregate deviation statistics between private ratings and SVO assessments; and adoption of the SVO’s original two-rating recommendation. None of these measures reprices a single credit. Each simply lets the market see what the referee sees.

The Price of an Unread Opinion

A credit rating is a compression algorithm. It takes everything knowable about a borrower and reduces it to a letter, so that capital can move quickly on trust, without every buyer re-underwriting every loan. The compression only works when someone, somewhere, can decompress it—test the letter against the loans, the price against the grade, the opinion against the outcome. Every mechanism performing that test in public markets—prices, short sellers, journalists, competing analysts, professional embarrassment—is absent by design from the private letter market. What remains is the incentive structure: the graded party chooses and pays the grader, one grade is enough, a higher grade is worth capital, and the grade will never be seen. The industry assures the market that professionalism fills the vacuum. The regulator’s own sample, and now four trillion dollars of academic evidence, suggest the vacuum is filling with notches.

The last time purchased grades set the capital requirements of systemically important institutions, the grades were at least public, and the reckoning arrived within a few years of the warnings. These grades are private, the institutions involved are stewards of American retirement promises, and the evidence has been accumulating in one direction for two years. Institutional investors do not need to wait for the cycle to render its verdict. The demands are simple, the disclosures are cheap, and the principle underneath them has not changed since 2008: an opinion that cannot be examined cannot responsibly be trusted with other people’s capital. The grade must earn its ink in daylight, or it should not be permitted to set the price of safety.

Referenced Sources:

1. Fitch Ratings, US Insurers and Private Credit: Not All Private Ratings Are the Same (Dec. 2024), https://assets.ctfassets.net/03fbs7oah13w/3kYIW8MRhmfLZPOtmnB5dn/0005ebfc614eca3982959da63485a9b3/FR-NAIC-Whitepaper-December-2024.pdf (summarizing, among other sources, NAIC Capital Markets Bureau, Private Ratings Among U.S. Insurer Bond Investments Continue to Rise and Have Nearly Tripled in Five Years (June 2024), subsequently removed from the NAIC’s website).

2. JLK Rosenberger, “Insurance Industry Private Credit Concentration” (June 4, 2026), https://jlkrosenberger.com/insurance-private-credit-concentration-federal-scrutiny/.

3. Bloomberg News, “Inflated ‘Private’ Ratings Are Masking Credit Risk, Columbia Study Says” (June 8, 2026), https://www.bloomberg.com/news/articles/2026-06-08/inflated-private-ratings-are-masking-credit-risk-columbia-study-says (republished by Advisor Perspectives, June 10, 2026, https://www.advisorperspectives.com/articles/2026/06/10/inflated-private-ratings-masking-credit-risk-columbia-study).

4. Capstone, “Insurers’ Increasing Exposure to Private Credit Attracts Regulators’ Scrutiny” (May 14, 2026), https://capstonedc.com/insights/insurers-increasing-exposure-to-private-credit-attracts-regulators-scrutiny/ (citing AM Best data).

5. “Study Says Life Insurers May Need $4.5B More Capital for Private Credit Holdings,” Institutional Investor (July 2026), https://www.institutionalinvestor.com/article/study-says-life-insurers-may-need-45b-more-capital-private-credit-holdings.

6. Xuelin Li, Sangmin Oh & Giacomo Ricciardi, Rating Without Market Discipline (Columbia Business School Research Paper, May 31, 2026), https://ssrn.com/abstract=6859158.

7. S&P Global Market Intelligence, “Holdings, Scrutiny of Private Letter Rated Bonds Continue to Climb” (Jan. 2026), https://www.spglobal.com/market-intelligence/en/news-insights/research/2026/01/holdings-scrutiny-of-private-letter-rated-bonds-continue-to-climb.

8. See Buxton Helmsley, “The Leveraged Opinion: How Private Equity Bought Its Way Into the Audit Profession—and What Institutional Investors Must Demand Before They Rely on the Next Clean Audit Report,” Insights (July 14, 2026).

9. See Buxton Helmsley, “The Last Line of Defense: How the Disappearance of Activist Short Sellers Is Leaving Corporate Fraud Undetected—and What Institutional Investors Must Do About It,” Insights (Mar. 10, 2026).

10. See Buxton Helmsley, “Marks Without a Market: How the Saba Tender Offers Exposed the Architecture of Private Credit Valuations—and What Institutional Investors Must Now Demand,” Insights (Apr. 29, 2026).

11. See Buxton Helmsley, “The Captive Float: How Private-Capital Managers Turned the American Annuity Into an Offshore Private-Credit Engine—and What Institutional Investors Must Demand Before They Trust the Balance Sheet Behind the Guarantee,” Insights (June 4, 2026).

12. New England Asset Management, “Latest NAIC RBC C1 for Life Insurers: Time to Reposition Your Portfolio?” (Oct. 2021), https://www.neamgroup.com/insights/latest-naic-rbc-c1-for-life-insurers-time-to-reposition-your-portfolio.

13. National Association of Insurance Commissioners, Purposes and Procedures Manual of the NAIC Investment Analysis Office (setting forth the filing-exemption framework under which securities rated by SEC-registered credit rating providers are exempt from independent Securities Valuation Office analysis).

14. International Monetary Fund, Global Financial Stability Report: Shifting Ground beneath the Calm (Oct. 2025), https://www.imf.org/-/media/files/publications/gfsr/2025/october/english/text.pdf; see also “The IMF Is Raising the Alarm on Insurance Investments in Private Credit,” Institutional Investor (Nov. 21, 2025), https://www.institutionalinvestor.com/article/imf-raising-alarm-insurance-investments-private-credit.

15. Silas Brown, Alexandre Rajbhandari & Laura Benitez, “A New Ratings Game: 3,000 Deals, 20 Analysts, Lots of Questions,” Bloomberg (June 1, 2025), https://www.bloomberg.com/news/articles/2025-06-01/private-credit-ratings-egan-jones-deals-raise-wall-street-scrutiny.

16. Isaac Taylor, “Private-Credit Ratings Under Scrutiny: Conflicting Interests Fuel Investor Concerns,” The Wall Street Journal (May 18, 2025), https://www.wsj.com/articles/private-credit-ratings-under-scrutiny-conflicting-interests-fuel-investor-concerns-b103830b.

17. Letter from Senator Elizabeth Warren to Sean J. Egan, Egan-Jones Ratings Company (July 17, 2025), https://www.banking.senate.gov/imo/media/doc/Warren%20Letter%20to%20Egan%20on%20Private%20Credit%20Ratings%20.pdf; see also Press Release, U.S. Senate Committee on Banking, Housing, and Urban Affairs (Minority), “Warren Calls for Stress Test on Private Credit, Presses Ratings Agencies on Inflated Private Credit Ratings” (July 17, 2025), https://www.banking.senate.gov/newsroom/minority/warren-calls-for-stress-test-on-private-credit-presses-ratings-agencies-on-inflated-private-credit-ratings.

18. Silas Brown, Alexandre Rajbhandari & Nicola M. White, “Egan-Jones Probed by SEC Over Its Credit Ratings Practices,” Bloomberg (Nov. 6, 2025), https://www.bloomberg.com/news/articles/2025-11-06/egan-jones-probed-by-sec-over-its-credit-ratings-practices.

19. Press Release, U.S. Securities and Exchange Commission, “Egan-Jones and Founder Sean Egan Agree to 18-Month Bars from Rating Asset-Backed and Government Securities Issuers as NRSRO” (Jan. 22, 2013), https://www.sec.gov/newsroom/press-releases/2013-2013-7htm.

20. Press Release, Egan-Jones Ratings Company, “Egan-Jones Responds to SEC Order for Formal Review of Application to Resume Rating of Issuers of Asset-Backed Securities and Government Securities” (Mar. 24, 2026), https://www.prnewswire.com/news-releases/egan-jones-responds-to-sec-order-for-formal-review-of-application-to-resume-rating-of-issuers-of-asset-backed-securities-and-government-securities-302722785.html.

21. Aysha Gilmore, “Insurers and Private Credit: Ratings Under the Microscope,” Alternative Credit Investor (Dec. 4, 2025), https://alternativecreditinvestor.com/2025/12/04/ratings-under-the-microscope/.

22. “Columbia Study Flags Potential Understatement of Risk in Private Credit Ratings,” Private Equity Wire (June 10, 2026), https://www.privateequitywire.co.uk/columbia-study-flags-potential-understatement-of-risk-in-private-credit-ratings/.

23. “KBRA Raises Concerns With Columbia Study Findings Linking Private Ratings to Life Insurer Capital Risks,” Private Equity Wire (June 11, 2026), https://www.privateequitywire.co.uk/kbra-raises-concerns-with-columbia-study-findings-linking-private-ratings-to-life-insurer-capital-risks/ (discussing Kroll Bond Rating Agency, Private Credit: Much Ado About Nothing—Perspectives on Columbia Business School Paper About Private Ratings (June 9, 2026)).

24. Financial Crisis Inquiry Commission, The Financial Crisis Inquiry Report 25 (Jan. 2011), https://fcic-static.law.stanford.edu/cdn_media/fcic-reports/fcic_final_report_full.pdf.

25. Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, § 939A, 124 Stat. 1376 (2010).

26. Akin Gump Strauss Hauer & Feld LLP, “Make (Whole) A Minute: The New Burden of Proof for Private Ratings,” https://www.akingump.com/en/insights/alerts/the-new-burden-of-proof-for-private-ratings (describing rationale-report requirements effective January 1, 2022).

27. Clifford Chance, “The NAIC’s Evolving Response to Private Equity in Insurance” (Mar. 2, 2026), https://www.cliffordchance.com/insights/resources/blogs/insurance-insights/2026/03/the-naics-evolving-response-to-private-equity-in-insurance.html.

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