Standard & Poor's, along with Moody's Investors Service and Fitch Ratings, downgraded billions of dollars structured transactions in the summer of 2007, resulting in a wave of criticism. So when Deven Sharma was named S&P president on Sept. 1 of that year, he kicked off a reform program that continues today.

The agency officially announced its reforms in February 2008. One of its first moves was to develop a rotation policy for ratings analysts who were seen as having developed overly cozy relationships with the companies whose debt they rated. Lead analysts for corporate ratings began rotating away from issuers every five years, while analysts leading structured ratings began rotations after reaching a defined level of issuance. "We looked to other industries for best practices, including different approaches for rotating personnel," said Edward Sweeney, an S&P spokesman.

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