Letters

Implementation of the Credit Rating Agency Reform Act of 2006

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rules implementing the Credit Rating Agency Reform Act of 2006, Release No. 34-55231.  SIFMA believes the section dealing, in the context of structured products, with the concerns over Nationally Recognized Statistical Rating Agencies (NRSRO) “notching” practices and contained in Section 17g-6 of the proposed rules should be both clarified and altered.

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