This article is a reprint of a study into the conflicts of interests inherent in the National Credit Agencies model of the US financial system that contributed to the Credit Crisis of 2009. I conducted this research while attending Fordham Law School in the Fall Semester of 2016.<\/p>\n\n\n\n
The risks arising out of potential conflicts of interests in business relationships has always been a concern for investors, starting from basic models like that of the principal-agent problem, to more complex problems, like pay-for-play schemes. Because of the recent Credit Crisis, public attention has been drawn to how national credit rating agencies (\u201cNCRAs\u201d) were compensated for providing rating service. The credibility of these institutions was called into question when it became apparent that they had incentives to issue good ratings on securities regardless of the risks that these securities presented to investors.<\/p>\n\n\n\n
Even before the Credit Crisis, Congress enacted the Credit Rating Agency Reform Act of 2006 (the \u201cReform Act\u201d) to provide the Securities Exchange Commission (\u201cSEC\u201d) with clearer authority to regulate credit rating agencies. While the Act did specify that the SEC had oversight authority in how NCRAs manage conflicts of interest, the act was mostly concerned with replacing the SEC\u2019s rudimentary procedure of using \u201cNo Action\u201d letters to designate NCRAs.[1]<\/a> It is only under the Dodd-Frank Act of 2010 that the SEC was now required to perform certain regulatory oversight studies and to guide them in promulgating new rules, one of which was to study conflicts of interests inherent at NCRAs.[2]<\/a><\/p>\n\n\n\n The product of this study was to identify ancillary (or consulting) services as a prominent force contributing to the conflict of interest problem. The report compared this issue to the separation of the research division at a broker-dealer from other divisions that may unduly influence analysts as was required by the Sarbanes-Oxley Act of 2002.[3]<\/a> Currently, the SEC\u2019s rules reflect this position, but the rules are also not particularly prohibitive.<\/p>\n\n\n\n This paper will take the position that NCRAs should be prohibited from offering any ancillary services and, instead, operate in the same way as a self-regulatory organization (\u201cSRO\u201d). In the alternative, this paper will also consider the intermediate position that NCRAs operate in the same way as national exchanges. This paper will begin by describing the business of NCRAs. Then this paper will identify the potential conflicts of interest that arise in NCRAs. Finally, this paper will outline how the SRO and national exchange models can better deal with these conflicts.<\/p>\n\n\n\nRead on to the next section…<\/a>\n\n\n\n [1]<\/a> See<\/em> 15 U.S.C \u00a7 78o-7(l)(2).<\/p>\n\n\n\n [2]<\/a> See<\/em> Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, 124 Stat. 1376 (2010) \u00a7\u00a7 939, 939C \u2013 939F.<\/p>\n\n\n\n [3]<\/a> See<\/em> Sarbanes-Oxley Act, Pub. L. No. 107-204, 116 Stat. 745 (2002) \u00a7 501.<\/p>\n\n\n\n\n\n\n\n Credit rating agencies (\u201cCRAs\u201d) provide services that can be categorized into credit rating services and ancillary services. Credit ratings are the primary service that CRAs provide and are designed to give investors a general sense of the risk level of a security. Ancillary services are typically consulting services that the CRA may provide to clients by tapping into the expertise of its employees \u2013 the credit ratings analysts. NCRAs are a subset of CRAs, and currently there are ten NCRAs registered with the SEC.[1]<\/a> This section provides an overview of how credit ratings work, what role NCRAs serve, and what conflicts of interest arise in this business.<\/p>\n\n\n\n Whenever a new security is issued, investors will need to assess the risk associated with the issuance, and CRAs provide a centralized way to perform the risk analysis. The SEC identifies five classes of issues with credit ratings: financial institutions, brokers or dealers; insurance companies; corporate issuers; issuers of asset-backed securities; and issuers of government securities, municipal securities or securities issued by a foreign government.[2]<\/a> Regardless of the class, a credit rating is designed to convey the probability of default (\u201cPD\u201d) or expected loss (\u201cEL\u201d) of an issue \u2013 whether it is the PD or EL depends on the methodology used by the rating agency.[3]<\/a><\/p>\n\n\n\n As a first step, rating agencies typically use a mathematical model to determine a credit score that represents the PD or EL for an issue. Then that issue is grouped with other issues that received similar scores, and an analyst determines how to rank these issues against one another, typically incorporating qualitative considerations at this step. Finally, all the issues are broken down into buckets that represent the best rated issues, second best, and so on. These buckets are more conventionally known as the credit rating.<\/p>\n\n\n\n For example, Standard & Poor\u2019s ratings for corporate issues represents the EL of the issue, and the best rating is expressed as AAA, followed by AA, A, BBB and so on. Moody\u2019s and Fitch Ratings use a similar taxonomy for corporate issues but their ratings represent the issue\u2019s PD. Ratings for other classes are generally the same, although the underlying model or procedure used to assess the PD or EL will likely differ.<\/p>\n\n\n\n Finally, while the credit rating is typically made publicly available to [2]<\/a>everyone with the issuer bearing the CRAs research cost, CRAs may provide more detailed analysis to investors for a fee. However, some CRAs may also charge investors for their credit ratings.<\/p>\n\n\n\n CRAs play a critical role in the securities investment industry. For example, funds use ratings to set cutoffs on what type of securities fund managers can incorporate into the fund\u2019s portfolio. But far more importantly, the ratings of certain CRAs can be used to satisfy the regulatory capital requirements of banks and other financial institutions. Depending on the credit rating assigned to an instrument, banks can assign better risk weights on investment grade assets to calculate capital ratios, or apply lower haircuts when using that asset as collateral.<\/p>\n\n\n\n The use of credit ratings for regulatory purposes is typically reserved to CRAs that the market deems to be reliable and credible. Although the Reform Act specifically prohibits registered NCRA from making certain representations about their status as NCRAs,[4]<\/a> NCRAs can claim that they are a registered NCRA.[5]<\/a> Thus, registering as a NCRA opens a CRA to new business potential.<\/p>\n\n\n\n By this framework, credit ratings turned into a big business industry, namely three big businesses \u2013 S&P, Moody\u2019s and Fitch \u2013 who together hold almost 95% market share of the credit rating services.[6]<\/a> Additionally, the SEC recognizes seven other NCRAs, for a total of ten.<\/p>\n\n\n\n Because of the issuer-backed payment model, and the ancillary services the NCRAs typically provide, these organization face a wide array of potential conflicts of interest. This section reviews the most prominent and controversial of these conflicts and how they are currently handled by U.S. laws.<\/p>\n\n\n\n The most reported potential conflict is that NCRAs are typically paid by issuers to issue a credit rating, and that they may also receive indirect compensation by rendering other consulting services to the issuer, which in some cases these consulting services are designed to improve the issuer\u2019s credit rating. The problem here arises from the issuer\u2019s goal of receiving the best possible credit rating, and the NCRA could seemingly be paid to inflate these ratings rather than maintaining independence. Additionally, NCRAs compete with one another for business, and this competition may [2]<\/a>not only be based on the cost of rating an issuer, but also on the NCRAs willingness to provide better ratings.<\/p>\n\n\n\n Pursuant to the Reform Act and the Dodd-Frank Act, the SEC enacted several rules to deal with this conflict. First, NCRAs must design and disclose procedures for managing conflicts that arise from being paid for ancillary services by issuers, underwriters or obligors (henceforth, collectively, \u201cissuers\u201d) when the NCRA was also paid by that issuer to determine a credit rating[7]<\/a> \u2013 note that investors are still able to pay NCRAs to issue credit ratings with no such restriction. Additionally, the NCRA must manage conflicts when anyone pays the NCRA for access to credit ratings or any other service, where that person receives a statutory or regulatory benefit from the NCRA\u2019s credit ratings.[8]<\/a> And so, the SEC chose the policy of managing and disclosing such conflicts rather than prohibiting the conflict altogether. However, NCRA\u2019s are prohibited from issuing or maintaining a credit rating solicited by anyone that provided 10% or more of the NCRA\u2019s total net revenue in the previous fiscal year[9]<\/a> \u2013 this prohibition is likely to disproportionately affect smaller NCRA issuers, so the SEC is allowed provide exemptions to smaller organizations on a case by case basis.[10]<\/a><\/p>\n\n\n\n Another controversial conflict that arises in the course of rating an issuer is that NCRA analysts would provide issuers with advice on how to structure a deal so as to improve the rating of the issue. Under the new rules, NCRAs are prohibited from issuing or maintaining a credit rating with respect to an obligor or security where the NCRA or employee of the NCRA made recommendations to the issuer or sponsor of the security about the corporate or legal structure, assets, liabilities, or activities of the issuer.[11]<\/a> The industry has been particularly critical of this rule, claiming that it compromises the honest attempt of issuers in structuring safer securities. However, this claim is merely a pretense from issuers trying to achieve high ratings in the most cost-effective way that avoids adhering to other possible credit enhancing procedures.[12]<\/a> Thus, the SEC\u2019s overall approach to dealing with conflicts of interest in the NCRA industry is to create barriers between research and sales[13]<\/a> \u2013 in a similar fashion to how Sarbanes-Oxley addressed this issue.[14]<\/a> This resulted in NCRAs splitting their organization into a credit ratings unit, and a consulting unit. However, none of these rules address the conflict inherent from the issuer-paid model that the larger NCRAs use, and the next section proposes ways to solve this problem.<\/p>\n\n\n\nRead on to the next section…<\/a>\n\n\n\n [1]<\/a> See<\/em> SEC, Report to Congress: Credit Rating Agency Independence Study<\/em> 7 (Nov. 2013), available at:<\/em> https:\/\/www.sec.gov\/news\/studies\/2013\/credit-rating-agency-independence-study-2013.pdf<\/a><\/p>\n\n\n\n [2]<\/a> See<\/em> Press Release, SEC, SEC Adopts Credit Rating Agency Reform Rules<\/em> (No. 2014-178, Aug. 27, 2014), available at:<\/em> https:\/\/www.sec.gov\/news\/pressrelease\/2014-178.html<\/a><\/p>\n\n\n\n [3]<\/a> A similar, although not identical, way of thinking about these two approaches, at least where corporate issuances are concerned, is whether the credit rating is specific to an issue or generic to an issuer.<\/p>\n\n\n\n [4]<\/a> 15 U.S.C \u00a7 78o\u20137(f)(1).<\/p>\n\n\n\n [5]<\/a> 15 U.S.C \u00a7 78o\u20137(f)(3).<\/p>\n\n\n\n [6]<\/a> See<\/em> Council on Foreign Relations, The Credit Rating Controversy<\/em> (Feb. 19, 2015), available at:<\/em> http:\/\/www.cfr.org\/financial-crises\/credit-rating-controversy\/p22328<\/a><\/p>\n\n\n\n [7]<\/a> 17 C.F.R. \u00a7 240.17g-5(b)(3).<\/p>\n\n\n\n [8]<\/a> 17 C.F.R. \u00a7 240.17g-5(b)(4).<\/p>\n\n\n\n [9]<\/a> 17 C.F.R. \u00a7 240.17g-5(c)(1).<\/p>\n\n\n\n [10]<\/a> 15 U.S.C \u00a7 78o\u20137(h)(3)(B)(i).<\/p>\n\n\n\n [11]<\/a> 17 C.F.R. \u00a7 240.17g-5(c)(5).<\/p>\n\n\n\n [12]<\/a> The simplest analogy of this conflict is to that of a municipality that uses hidden police cars to enforce speed limits. The effectiveness of using hidden enforcers is that drivers will not know their locations, and thus will be more likely to adhere to speed limits everywhere. However, drivers that know the exact locations of all hidden police officers will only obey the speed limits in those areas, thus compromising the purpose of enforcing the speed limit.<\/p>\n\n\n\n [13]<\/a> The new regulation also includes \u201clook-back\u201d rules that are designed to manage how employees of NCRAs may be incentivized to inflate credit ratings. See<\/em> 15 U.S.C \u00a7 78o\u20137(h)(4). However, this paper will not examine these rules because they do not deal with organizational issues discussed in this paper.<\/p>\n\n\n\n [14]<\/a> See <\/em>Sarbanes-Oxley Act supra <\/em>n. 5.<\/p>\n\n\n\n\n\n\n\n In \u00a7 II.C<\/strong> this paper examined the various conflicts of interest arising out of an NCRA business and how Congress and the SEC addressed those issues. However, the conflict of issuer-paid credit rating services was still not addressed \u2013 the only such attempt is the 10% prohibition imposed by rule 17g-5(c)(1), which suffice it to say is a very lax prohibition.[1]<\/a> The problem with rule 17g(c)(1) is two-fold. Firstly, the three large credit rating agencies are unlikely to trigger the 10% level due to the number of clients they have and their diverse lines of business. Secondly, smaller institutions are likely to receive an exemption from the SEC[2]<\/a> in order to promote competition in the credit ratings industry.[3]<\/a><\/p>\n\n\n\n Simply doing away with the issuer paid model is not a reasonable solution to this problem. NCRAs serve an important public purpose and prohibiting issuers from paying for credit rating services would only serve to reduce transparency in the long run. This section proposes a way to solve this problem by introducing two different models for structuring this industry.<\/p>\n\n\n\n One way of addressing the 17g-5(c)(1) problem is to directly admit to the public purpose of credit ratings, and run the business like a SRO \u2013 namely, FINRA (the Financial Industry Regulatory Authority).[4]<\/a> One of FINRA\u2019s top priorities that closely resembles the purpose of NCRAs is \u201cto advance investor confidence in the security markets through vigorous, fair and effective enforcement.\u201d[5]<\/a><\/p>\n\n\n\n FINRA is a non-profit association regulated by the SEC that also exercises regulatory authority over member organizations, where registration is required of all broker-dealers but subject to certain exemptions.[6]<\/a> FINRA serves in its SRO capacity alone,[7]<\/a> with some overlap with national exchanges, further discussed below. FINRA is primarily funded through various fees paid by member firms \u2013 trading activity fee, gross income assessment, personnel assessment and branch office assessment. As such, FINRA also follows a model similar to an issuer-paid model.<\/p>\n\n\n\n FINRA was initially criticized for levying smaller fines each year on a gross annual basis during the period of 2005 to 2008 \u2013 a steady decline from $184 million in 2005 to $28 million in 2008.[8]<\/a> However, this trend did not continue, and in 2015 FINRA levied about $95 million in fines.[9]<\/a> The organization has generally been positively received by both the industry and the SEC \u2013 in particular, the industry has an incentive to maintain integrity because it promotes higher capital investments.<\/p>\n\n\n\n In a similar manner, the SEC can enact only one non-profit ratings association in charge of issuing ratings for a certain class of securities or issuances. The association would be funded by issuers, but the 17g-5(c)(1) problem would be solved by removing potential credit rating shopping by issuers. If an issuer, or sponsoring firm, would like to benefit from NCRA ratings or comply with rules that require the issuance of NCRA ratings, then they must become members.<\/p>\n\n\n\n However, this model would go in direct opposition to the SEC\u2019s current goal of promoting competition in the NCRA space. And unlike enforcement actions, credit ratings are much more susceptible to varying opinions by different analysts and the process is not subject to anything resembling judicial oversight. Therefore, while this model may present a long run approach toward which the SEC must strive, it may be more practical to consider an intermediate approach in the short term, as outlined in the following section.<\/p>\n\n\n\n National exchanges are organizations or associations designed as a venue for trading securities[10]<\/a> by setting rules to regulate the trading activities of member firms.[11]<\/a> Only brokers or dealer may become exchange members,[12]<\/a> and other investors seeking to trade exchange traded securities must do so through a broker-dealer. Thus, exchanges are a type of broker-dealer for broker-dealers, and for the most part a registered broker-dealer can function as an exchange, but it would fail to meet the definition of an exchange if it does not regulate its clients \u2013 these broker-dealers typically fall under the definition of an alternative trading system.<\/p>\n\n\n\n The primary regulatory framework for exchanges is known as Reg NMS, which is a set of rules designed to unify an otherwise fragmented market system and facilitate a national market system in its place.[13]<\/a> These rules are designed to promote competition not through exemption but by requiring that exchanges route orders to other exchanges if a better price exists at the other exchange.[14]<\/a> And so exchanges generally compete across other factors, like the type of services they may offer.<\/p>\n\n\n\n Similarly, we offer two ways that the NCRA industry can be reformed, but explain why only one of those ways is the better option. In the first way, the SEC can require that NCRAs must bid for rating business in some type of auction system. This would mean that NCRAs would compete on price rather than on their willingness to issue better ratings. However, this would also create a race-to-the-bottom problem that is seen in other industries that compete on price at the expense of quality \u2013 e.g. insurance. The second way would involve establishing a price setting committee that would establish a flat fee for rating services across the industry, however, any NCRA would be permitted to issue a rating and may share in the fee. As a quid-pro-quo, an NCRA that partakes in the fee must publicly publish their rating.<\/p>\n\n\n\n There are a few reasons why this second approach would be superior. Firstly, it removes the conflict of interest problem created by the issuer-paid model by removing the choice of where issuers purchase rating services. Secondly, while NCRAs must publicly publish the rating, they may also offer additional analysis for a fee to subscribers, and so NCRAs would compete among each other on quality of service from the perspective of an investor \u2013 rather than quality from the perspective of an issuer. Thirdly, because NCRAs are designated by the SEC through a rulemaking process, there is at least some level of control that would prevent an inundation of services by agencies that are simply seeking to make a grab at a share of the flat fee, and in this way the NCRAs can exercise some control over issuers rather than issuers exercising control over NCRAs. Finally, by publishing more than one credit rating, investors receive several analyst opinions and, thus, a more transparent view of new issuances. The second method displays stark similarities to the NMS model, because it provides a way for competing NCRAs to access clients of other NCRAs, while at the same time keeping competition on quality of service and removing the influence of issuers on the selection and price setting process. And just as how Reg NMS has helped improve the national market system, the reform explained in this section can help improve the NCRA system. The only real drawback to this system is that the three big NCRAs are likely to heavily lobby against it because it challenges their monopoly over issuer-paid credit rating services.<\/p>\n\n\n\nRead on to the next section…<\/a>\n\n\n\n [1]<\/a> See<\/em> supra<\/em> n. 15.<\/p>\n\n\n\n [2]<\/a> See supra<\/em> n. 16<\/p>\n\n\n\n [3]<\/a> See e.g.<\/em> Order Granting Temp. Exemption of Morningstar Credit Ratings, LLC from the Conflict of Interest Prohibition in Rule 17g-5(c)(1) of the Sec. Exch. Act of 1934<\/em>, Release No. 66514 (Mar. 5, 2012), Order Granting Temp. Exemption of Kroll Bond Rating Agency, Inc. from the Conflict of Interest Prohibition in Rule 17g-5(c)(1) of the Sec. Exch. Act of 1934<\/em>, Release No. 65339 (Sept. 14, 2011), Order Granting Temporary Exemption of LACE Financial Corp. from the Conflict of Interest Prohibition in Rule 17a-5(c)(1) of the Securities Exchange Act of 1934<\/em>, Release No. 57301 (Feb. 14, 2008).<\/p>\n\n\n\n [4]<\/a> FINRA is a SRO dedicated to investor protection and market integrity through effective regulation of broker-dealers. See<\/em> FINRA, About FINRA, https:\/\/www.finra.org\/about<\/a><\/p>\n\n\n\n [5]<\/a> See<\/em> FINRA, Enforcement, https:\/\/www.finra.org\/industry\/enforcement<\/a><\/p>\n\n\n\n [6]<\/a> See<\/em> 15 U.S.C \u00a7 78o(b)(1)(B).<\/p>\n\n\n\n [7]<\/a> This was the result of combining the National Association of Securities Dealers with the New York Stock Exchange Regulation, Inc.<\/p>\n\n\n\n [8]<\/a> See<\/em> Deborah Heilizer, Brian Rubin, and Andrew McCormick, Annual Sutherland Analysis of FINRA<\/em> (Feb. 24, 2014), available at:<\/em> http:\/\/www.sutherland.com\/NewsCommentary\/Press-Releases\/161244\/Annual-Sutherland-Analysis-of-FINRA-Sanctions-Shows-27-Decrease-in-Fines-Number-of-Cases-Nearly-Identical<\/a><\/p>\n\n\n\n [9]<\/a> See<\/em> FINRA, What We Do, https:\/\/www.finra.org\/about\/what-we-do<\/a><\/p>\n\n\n\n [10]<\/a> 15 U.S.C \u00a7 78c(a)(1).<\/p>\n\n\n\n [11]<\/a> 17 C.F.R. \u00a7 240.3b-16(a)(2).<\/p>\n\n\n\n [12]<\/a> 15 U.S.C \u00a7 78c(a)(3).<\/p>\n\n\n\n [13]<\/a> See<\/em> Regulation NMS, <\/em>70 Fed. Reg. 37,496, 37,498-501 (\u201cNMS Principles and Objective\u201d).<\/p>\n\n\n\n [14]<\/a> See<\/em> 17 C.F.R. \u00a7\u00a7 242.610, 242.611 (the \u201cAccess Rule\u201d and \u201cTrade-through Rule,\u201d respectively).<\/p>\n\n\n\n\n\n\n\n This paper examined the conflict of interest inherent in the NCRA industry, and sought to directly address the potential conflict of the issuer-paid model. The paper showed that, firstly, the SEC\u2019s only solution using rule 17g-5(c)(1) is merely window dressing and not a solution, and secondly, better frameworks exist to deal with this conflict. The first solution uses the SRO model by creating a single agency that handles ratings and removing the choice from issuers. The second solution uses the national exchange model, where the power to select and influence credit ratings is shifted from issuers to investors and NCRAs. While both solutions directly address the issuer-paid conflict, the exchange model may be more practical as an immediate reform. Under both approaches, NCRAs would be prohibited from offering ancillary services to issuers.<\/p>\n\n\n\n This article is a reprint of a study into the conflicts of interests inherent in the National Credit Agencies model of the US financial system that contributed to the Credit Crisis of 2009. I conducted this research while attending Fordham Law School in the Fall Semester of 2016.<\/p>\n","protected":false},"excerpt":{"rendered":" This article is a reprint of a study into the conflicts of interests inherent in the National Credit Agencies model of the US financial system that contributed to the Credit …<\/p>\n","protected":false},"author":1,"featured_media":344,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[77,75],"tags":[],"class_list":["post-338","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-finance","category-law"],"_links":{"self":[{"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/posts\/338","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/comments?post=338"}],"version-history":[{"count":32,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/posts\/338\/revisions"}],"predecessor-version":[{"id":838,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/posts\/338\/revisions\/838"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/media\/344"}],"wp:attachment":[{"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/media?parent=338"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/categories?post=338"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.riskideas.com\/index.php\/wp-json\/wp\/v2\/tags?post=338"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\n\n\n\nThe Business of National Credit Rating Agencies<\/h3>\n\n\n
Table of Contents<\/h4>
\n\n\n\nCredit Ratings<\/h4>\n\n\n\n
\n\n\n\nNCRAs<\/h4>\n\n\n\n
\n\n\n\nConflicts of Interest<\/h4>\n\n\n\n
\n\n\n\nNCRA Issuer-Paid Model Reform<\/h3>\n\n\n
Table of Contents<\/h4>
\n\n\n\nSelf-Regulatory Organization Model<\/h4>\n\n\n\n
\n\n\n\nNational Exchange Model<\/h4>\n\n\n\n
\n\n\n\nConclusion<\/h3>\n\n\n
Table of Contents<\/h4>
\n\n\n\n