Rescission of a Rule Under the Securities Act of 1933

SIFMA’s Credit Rating Agency Task Force provides comments to the Securities and Exchange Commission (SEC) comments regarding the possible recession of Rule 436(g) under the Securities Act, which exempts NRSRO from being held accountable for their credit ratings, SEC Release Nos. 33-9071, 34-60798, IC-28943, File No. S7-25-09. The Task Force has not yet reached uniformed agreement supporting either the removal or maintenance of the existing rule. The Task Force supports SEC efforts to improve investor protection in relation to credit rating agencies but urge the SEC to take into consider the whether the recession of Rule 436(g) will result in any unintended consequences that could negatively affect the financial markets.