SEC’s Pending Study on Assigned Credit Ratings

The SIFMA Securitization Group (SSG) provides comments to the Securities and Exchange Commission (SEC) on the SEC’s Solicitation of Comment To Assist in Study on Assigned Credit Ratings. This study is being performed according to Section 939F of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), and is a prelude to a very important rulemaking the SEC must undertake in 2012 related to the assignment of credit ratings to structured finance products.  SIFMA urges the SEC to gather as much information as possible, so as to be able to perform a sound and robust analysis of the costs and benefits of the approach prescribed in Section 939F of the Dodd-Frank Act, the so-called “Section 15E(w) System”, and the various alternatives to that approach.