Abstract: Governmental bodies are increasingly incorporating the work of private credit rating agencies into regulatory standards. In this comment, Professor Jackson examines how a recent proposal of Basel Committee on Banking Supervision would extend this practice by factoring the credit ratings of borrowers into capital adequacy requirements for commercial banks. After reviewing various criticisms of the Basel Committee's proposal, the Comment considers alternative approaches to measuring the credit risk of commercial banks and concludes with a discussion of implications for regulatory policy in a global financial services industry.