The purpose of this Comment is to evaluate how criminal disincentives affect the credit ratings agencies.  The Comment explores how the criminal law influenced the behavior of the ratings agencies before and during the subprime collapse and the credit crisis.  The failures of the ratings agencies have led to a widespread push for regulatory reform, but the possibility of a targeted criminal law has been largely absent from the scholarly and political discourse.  This Comment examines why there have been no criminal prosecutions against actors at the ratings agencies, particularly in light of their heavily criticized role in the credit crisis.  In finding criminal liability difficult to establish under the existing law, this Comment suggests that a tailored criminal law targeting the ratings agencies would provide a justifiable and powerful control mechanism for high-risk misconduct.  Although strict civil laws could similarly deter misconduct, compliance with and enforcement of civil regulations would be inefficient and expensive.