CREATURE — CREDIT RATER
Issuer-Pays Model⊙ 2Target debt issuer gains +3 defense. If that issuer pays you 1 gold, draw a card. (This ability reflects the issuer-pays compensation structure.)
NRSRO Designation⊙ 3Until your next turn, your ratings cannot be questioned by regulatory effects. (Moody's has been an NRSRO since 1975.)
Settlement Restructuring⊙ 5Pay 863.8 million gold to remove all negative effects from your board. Then, separate your analytical and commercial goblins for 5 turns. (This ability reflects the 2017 settlement terms.)
Public records show Moody's settled allegations of inflated ratings on RMBS and CDOs for $863.8 million in 2017. Regulatory fines include €3.7 million from ESMA in 2021 for conflict-of-interest breaches and $20 million from the SEC in 2024 for record-keeping failures.
#credit rater#issuer-pays#nrsro#regulatory capture
