Proposed Rulemakings Related to Credit Ratings

The Capital Markets Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on  the SEC’s proposed rulemakings related to credit ratings, Release No. 33-9186; 34-63874; File No. S7-18-08. The proposal addresses the removal of references to credit ratings in short form registration requirements, particularly on Form S-3/F-3.  The Proposing Release contains proposed rule and form amendments under the Securities Act of 1933 and the Securities Exchange Act of 1934. These amendments generally respond to the requirements of Section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).  SIFMA outlines its recommendations and observations, including provisions of the proposal that may have unintended consequences for market participants.