While RIMS said it does not advocate the use of one ERM framework over another, it congratulated S&P on its work to date and its forward-thinking approach for recognizing the value of ERM in evaluating the credit quality of a broad cross-section of companies.

In its comments, RIMS said S&P's rating approach "drives ERM from a sometimes difficult-to-define concept to a management practice that directly and visibly impacts the organization."

RIMS added that the framework also will compel "corporate decision-makers to explicitly consider risk. This is something many companies are probably doing on an informal basis, but S&P's focus on ERM and its independent rating will improve that process by driving management to a more formal methodology in order to address S&P's inquiry."

RIMS said it supports S&P's adoption of an ERM framework as a component of its ratings reviews because a well-implemented ERM program is characteristic of a well-managed company "and does indeed enhance an organization's credit quality to investors and shareholders."

While the S&P assessment framework provides certain structural requirements for an ERM program, RIMS said there is room for improvement.

RIMS said it encourages S&P to consider whether its framework and evaluation process is flexible enough to fit any given company's culture and management style, particularly with S&P's apparent focus on applying a sector-specific platform.

RIMS also asked S&P to carefully consider the different operating perspectives of financial institutions and nonfinancial companies, and take these differences into account as it transitions the assessments for nonfinancial companies.

RIMS suggested that S&P consider a continuum of ERM maturity in assigning its ratings--offering its Risk Maturity Model as a tool for consideration.

The association said it "looks forward to continuing to work with S&P in order to accelerate ERM best practices across all industries."