On August 10th, the New York Times (the "Times") summarized S&P's 84-page response to the Commission's proposed rules for credit ratings agencies. S&P's comments take particular aim at the Commission's proposed requirement that ratings agencies disclose "significant errors." The Times noted that S&P's comments were submitted three days after it downgraded the Federal government's credit rating and after the Treasury Department accused S&P of having committed a $2 trillion math error. Comments.