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The Office of Credit Ratings is considering recommending that the Commission propose rules and amendments designed to address the conflicts of interest associated with the issuer-pay business model (i.e., the NRSRO receives compensation from issuers and obligors for rating the securities of the issuer or the obligor) and increase  transparency and promote competition for the ratings of securities. The recommendation would include proposed rules and amendments designed to increase transparency of (i) the procedures and methodologies NRSROs use to determine credit ratings and how the NRSROs implement their procedures and methodologies, including qualitative factors considered, and adherence to and deviations from established procedures and methodologies; and (ii) climate and ESG factors considered as part of the rating determination process.