It probably is a fish.
WASHINGTON — The internal procedures of one of the world’s top three ratings agencies appear to allow leaks of its decisions, according to a report by the US Securities and Exchange Commission (SEC).
At one of the larger agencies, “the procedures for disseminating a pending rating action appeared to allow for limited dissemination of a pending rating action in some instances prior to public dissemination,” the report said. [...]
Annual checks of the agencies were introduced under a financial reform law that came into effect in July last year. Up until then, the checks were carried out every two years.
Allows for limited dissemination of a pending rating action.
I read that as "allows for a limited number of people to engage in insider trading."
While the report does not name names, it's pretty obvious who the culprit is. S&P is the only agency which chose to downgrade the U.S. credit rating over the summer and the U.S. government was the last to know about it.
It should be noted that if it weren't for the Dodd-Frank financial reform law passed by the Obama Administration and the Democratically-controlled Congress of 2009-2010, this report issued by the SEC would not occur until next year.