The Consumer Federation of America (CFA) urges the Commission to re-propose and extensively revise rule changes relating to credit rating agencies registered with the Commission as Nationally Recognized Statistical Rating Organizations (NRSROs). We previously expressed our concerns with the Commission’s proposed rule when it was first published and made available for public comment in 2011. We reiterate here the points we made in our previous comment, as the proposed regulations did not match the scale of the problem they were intended to address, nor did they deliver the full scope of the credit rating agency reforms that Congress intended when it adopted the Dodd-Frank Act.