The comments address (a) the value of ERM as a way to assess how well a company is managed, (b) that the S&P definition of risk should be expanded to include many operational risks that are not typically included in financial risk models, (c) that S&P retain broad flexibility when defining sector-specific risks, (d) that S&P consider adopting a maturity model in assigning its rankings, and (e) that based on RIMS surveys, nonfinancial companies are ready to begin implementation of ERM. #Article #EnterpriseRiskManagement