The SEC appointed Jonny Frank as the Independent Consultant to a Big Three credit rating agency, following its failure to establish, maintain and document an effective internal control structure governing the use of certain models in its methodology for rating U.S. Residential Mortgage-Backed Securities (RMBS). In this matter, Jonny and the StoneTurn team analyzed and tested key controls supporting the use of models in the RMBS credit rating process to determine their effectiveness at preventing, detecting and remedying model errors. StoneTurn professionals documented their findings and recommendations in a formal report and partnered with the client to implement recommended improvements to its internal control structure.