It’s taken nearly three months, but ASIC finally has enough of a grip on itself and the issues to name the issuers of unrated and unlisted debentures that the watchpuppy regards as the most risky in the wake of Westpoint, Fincorp and ACR.

That’s the list it refused to give to us on June 6 but now all the names, products and yields are disclosed as an appendix to its discussion paper on ASIC’s Three Point Plan (their caps, not ours) for dealing with the scandal.

It’s a minor point that the 83 issuers ASIC boss Tony D’Aloisio told the parliamentary committee about in May has grown to 92. The harsher critics might say the whole discussion paper is a minor point as it still relies on improving disclosure rather than any vetting or detective work. And, therefore, it still relies on retail investors being able to smell a rat in a cheese factory – something many are demonstrably unable to do.

ASIC does plenty of blame-shifting in the process. It starts by stressing the disclosure rather than policing route is federal government policy – so don’t blame ASIC or its servants if it all goes wrong. With that established, responsibility for cleaning up the high-yield debenture business is passed on to everyone except ASIC – ratings agencies, auditors, trustees, even media organisations who are supposed to determine if debenture advertising standards are acceptable.

There are some good ideas along the way, but the bottom line remains nothing more than “if not, why not” disclosure requirements. And as long as a substantial number of mug punters see no further than the interest rate on offer, what’s goes into the prospectus will often stay in the prospectus.

But there are a couple of intriguing hints in the discussion paper that ASIC is taking aim at other targets, including one that it actually has the power to hit.

Reading the paper, you might form the opinion that ASIC doesn’t think much of the second-tier “independent experts” and ratings agencies that service the lower end of the market. And that it thinks there’s skulduggery afoot in the managed investment scheme industry that needs the same sort of increased disclosure that it wants to see in debentures.

Basically, ASIC hopes to clean up the unrated debenture market by leaning on it to become rated, but it wants it rated by “recognised” ratings agencies.

The sting is that ASIC only “recognises” three ratings agencies – the big three, Moody’s, Standard & Poor’s and Fitch. Never mind for the moment that these are the boys who enabled the CDO scandal, it looks like ASIC wants to clean up the lesser local credit raters as much as it wants to deal with debenture issuers.

And then there’s this little overlooked paragraph:

When we finalise our policy on unlisted, unrated debentures, we will consider whether a similar approach is appropriate for any other sectors, including some managed investment schemes.

The word “rural” is not in front of MIS, but it may as well be. Some of the “investment” ratings tossed around in that sector by alleged experts could well have trouble being “recognised”.

The watchpuppy’s yap might deepen to a bark yet.