Unsolicited ratings have long been overlooked in the investment landscape and issuer pay models. Although Congress has lost its confidence in the credit rating agencies’ reputation theory and is now considering a semi-closed market as the only viable solution to the conflict of interest problem, financial scholars have proposed the Inequality model using unsolicited ratings and focusing on a reputational theory that could lead to more stringent rating standards. This Note argues that it is possible to achieve the Inequality for unsolicited ratings by utilizing the already required disclosures and making a few enhancements. This Note proposes that this will in turn improve accuracy and combat the conflict of interest problem without deviating from free market principles.



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