Certain References to Ratings in Their Regulations

Published on:
April 18, 2011

The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended, (the 1940 Act) to implement Section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). Section 939A directs certain Federal agencies, including the SEC, to review and eliminate certain references to ratings in their regulations.  SIFMA AMG’s correspondence includes the following points:

  • Rule 2a-7 forbids the reliance on credit ratings as an assessment of creditworthiness, therefore Section 939A of Dodd-Frank does not apply to Rule 2a-7;
  • Credit ratings benefit shareholders by serving as a quality floor, which is different than the provisions in other regulations;
  • Form N-MFP should not be altered because it is a disclosure form and is not required for quality assessment; and,
  • If the commission determines that Section 939A requires removal of the references, then Congress should explore the possibility that additional credit analysis be mandated rather than the removal of ratings references.

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.