... by at least one NRSRO approved by the Commission, and within one of the two highest rating categories established by the Securities Valuation Office (“SVO”) of the National Association of Insurance ... investors and other market participants had increased significantly, impacting an issuer’s access to and cost of capital, the structure of financial transactions, and the ability of fiduciaries and ... agencies in the U.S. securities markets.55 The purpose of the Order was to ascertain facts, conditions, practices, and other matters relating to the role of rating agencies in the U.S. securities...