Egan-Jones (an independent NRSRO with no-conflicts-of-interest) provides short term ratings for money market funds which fully satisfy new 2a-7 requirements.

Federal Reserve Bank study

Direct excerpts and conclusions:

Overall, it is robustly the case that S&P's re-grades moved in the direction of EJR's earlier ratings. It appears more likely that this result reflects systematic differences between the two firms rating policies than a small number of lucky guesses by EJR.

A comparison between S&P's and EJR's ratings shows that, conditional on S&P's upgrading or downgrading a firm,its new grade was correlated with the grade EJR had awarded at least ten weeks earlier. This suggests that S&P defines its ratings more widely in terms of default probabilities than EJR.

It also suggests that S&P's large downgrades do not occur immediately after negative surprises to firms, but rather after a steady accumulation of bad news which EJR's ratings previously reflected".

S&P ratings converge toward Egan-Jones Ratings.

Richard Johnson, Research Division, Federal Reserve Bank of Kansas City, Feb 2003, RWP030.

Stanford University and University of Michigan studies

Direct excerpts and conclusions:

Credit ratings from Egan-Jones more accurately reflect information in the marketplace and are frequently up to 237 days ahead of actions taken by Moody's and S&P.

The powerful market incentives resulting from the investor supported, independent business model of Egan-Jones Ratings Company produces more timely and accurate ratings with predictive value.

William H Beaver, Graduate School of Business, Stanford University, Stanford Ca 94305

Catherine Shakespere, Mark T. Soliman, University of Michigan, Ann Arbor Mi. 48109.

First version 2003, Second version, June 2006.