Action against Respondent, a nationally recognized statistical rating organization, for alleged failure to establish, maintain, enforce, and document an effective internal control structure with regard to its use of certain models in connection with its methodology for rating residential mortgage-backed securities (“RMBS”). According to the SEC, Respondent revised its methodology for rating RMBS by incorporating cash flow waterfall models developed by its corporate affiliate. The SEC alleges that Respondent established policies and procedures that prescribed oversight responsibilities over third party providers but failed to apply the guidelines to its affiliate or establish and document reasonably designed internal controls with respect to the relevant models. The SEC alleges that, accordingly, Respondent failed to conduct or take reasonable steps to ensure its affiliate conducted adequate quality control assurance processes with regard to the models, leading to various errors. Respondent has agreed to pay a civil penalty of $15,000,000.