On September 30, the SEC issued its annual report, as required under the Dodd-Frank Act, summarizing its findings after examining the practices of credit rating agencies registered with the SEC as NRSROs and subject to SEC oversight.  The concerns outlined in the report include, in some instances, apparent failures by NRSROs to: (i) follow rating methodologies and procedures; (ii) make timely and accurate disclosures; (iii) establish effective internal control structures for the rating process; and (iv) adequately manage conflicts of interest.  SEC ReleaseSEC Report.