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 FINANCIAL CRISIS INQUIRY COMMISSION REPORT

quality.  He testified to the FCIC, “We believed that our ratings were our best opinion
at the time that we assigned them. As we obtained new information and were able to
update our judgments based on the new information and the trends we were seeing in
the housing market, we made what I think are appropriate changes to our ratings.” 
Nonetheless, Moody’s president did not seem to have the same enthusiasm for
compliance as he did for market share and profit, according to those who worked
with him. Scott McCleskey, a former chief compliance officer at Moody’s, recounted a
story to the FCIC about an evening when he and Clarkson were dining with the
board of directors after the company had announced strong earnings, particularly in
the business of rating mortgage-backed securities and CDOs. “So Brian Clarkson
comes up to me, in front of everybody at the table, including board members, and
says literally, ‘How much revenue did Compliance bring in this quarter? Nothing.
Nothing.’ . . . For him to say that in front of the board, that’s just so telling of how he
felt that he was bulletproof. . . . For him, it was all about revenue.”  Clarkson told the
FCIC that he didn’t remember this conversation transpiring and said, “From my per-
spective, compliance is a very important function.” 
According to some former Moody’s employees, Clarkson’s management style left
little room for discussion or dissent. Witt referred to Clarkson as the “dictator” of
Moody’s and said that if he asked an employee to do something, “either you comply
with his request or you start looking for another job.”  “When I joined Moody’s in
late , an analyst’s worst fear was that we would contribute to the assignment of a
rating that was wrong,” Mark Froeba, former senior vice president, testified to the
FCIC. “When I left Moody’s, an analyst’s worst fear was that he would do something,
or she, that would allow him or her to be singled out for jeopardizing Moody’s mar-
ket share.”  Clarkson denied having a “forceful” management style, and his supervi-
sor, Raymond McDaniel, told the FCIC that Clarkson was a “good manager.” 
Former team managing director Gary Witt recalled that he received a monthly
email from Clarkson “that outlined basically my market share in the areas that I was
in charge of. . . . I believe it listed the deals that we did, and then it would list the deals
like S&P and/or Fitch did that we didn’t do that was in my area. And at times, I would
have to comment on that verbally or even write a written report about—you know,
look into what was it about that deal, why did we not rate it. So, you know, it was clear
that market share was important to him.” Witt acknowledged the pressures that he
felt as a manager: “When I was an analyst, I just thought about getting the deals
right. . . . Once I [was promoted to managing director and] had a budget to meet, I
had salaries to pay, I started thinking bigger picture. I started realizing, yes, we do
have shareholders and, yes, they deserved to make some money. We need to get the
ratings right first, that’s the most important thing; but you do have to think about
market share.” 
Even as far back as , a strong emphasis on market share was evident in em-
ployee performance evaluations. In July , Clarkson circulated a spreadsheet to
subordinates that listed  analysts and the number and dollar volume of deals each
had “rated” or “NOT rated.” Clarkson’s instructions: “You should be using this in PE’s