MOODY’S: “IT WAS ALL ABOUT REVENUE” Like other market participants, Moody’s Investors Service, one of the three dominant rating agencies, was swept up in the frenzy of the structured products market. The tranching structure of mortgage-backed securities and CDOs was standardized according to guidelines set by the agencies; without their models and their generous allotment of triple-A ratings, there would have been little investor interest and few deals. Between 2002 and 2006, the volume of Moody’s business devoted to rating residential mortgage–backed securities more than doubled; the dollar value of that business increased from $62 million to $169 million; the number of staff rating these deals doubled. But over the same period, while the volume of CDOs to be rated increased sevenfold, staffing increased only 24%. From 2003 to 2006, annual revenue tied to CDOs grew from $12 million to $91 million. When Moody’s Corporation went public in 2000 , the investor Warren Buffett’s Berkshire Hathaway held 15% of the company. After share repurchases by Moody’s Corporation, Berkshire Hathaway’s holdings of outstanding shares increased to over 20% by 2008. As of 2010, Berkshire Hathaway and three other investors owned a combined 50.5% of Moody’s. When asked whether he was satisfied with the internal controls at Moody’s, Buffett responded to the FCIC that he knew nothing about the management of Moody’s. “I had no idea. I’d never been at Moody’s, I don’t know where they are located.” Buffett said that he invested in the company because the rating agency business was “a natural duopoly,” which gave it “incredible” pricing power and “the single-most important decision in evaluating a business is pricing power.” Many former employees said that after the public listing, the company culture changed—it went “from [a culture] resembling a university academic department to one which values revenues at all costs,” according to Eric Kolchinsky, a former managing director. Employees also identified a new focus on market share directed by former president of Moody’s Investors Service Brian Clarkson. Clarkson had joined Moody’s in 1991 as a senior analyst in the residential mortgage group, and after successive promotions he became co-chief operating officer of the rating agency in 2004, and then president in August 2007. Gary Witt, a former team managing director covering U.S. derivatives, described the cultural transformation under Clarkson: “My kind of working hypothesis was that [former chairman and CEO] John Rutherford was thinking, ‘I want to remake the culture of this company to increase profitability dramatically [after Moody’s became an independent corporation],’ and that he made personnel decisions to make that happen, and he was successful in that regard. And that was why Brian Clarkson’s rise was so meteoric: . . . he was the enforcer who could change the culture to have more focus on market share.” The former managing director Jerome Fons, who was responsible for assembling an internal history of Moody’s, agreed: “The main problem was . . . that the firm became so focused, particularly the structured area, on revenues, on market share, and the ambitions of Brian Clarkson, that they willingly looked the other way, traded the firm’s reputation for short-term profits.”