Events Calendar
News and Information for and by the Securitization Industry
Related Pages:
SEC ‘No Action’ Letter Adopts ASF Recommendation to Temporarily Omit Ratings in Registration Statements on July 22, 2010
The SEC’s Division of Corporation Finance has issued a ‘no action’ letter allowing issuers for a period of 6 months to omit credit ratings from registration statements filed under Regulation AB. This ‘no action’ letter relates to the repeal of Rule 436(g), effective July 22, under the “Dodd-Frank Wall Street Reform and Consumer Protection Act.” In a letter sent to the SEC today, the ASF specifically requested that the SEC temporarily provide that “disclosure of ratings is not required for issuers of asset-backed securities under Item 1103(a)(9) or Item 1120 of Regulation AB.” The ‘no action’ letter materially responds to this request and the ASF applauds the SEC’s decision to resolve the uncertainty surrounding the public ABS market. Please click here for the ‘no-action’ letter. Please click here for ASF’s letter to the SEC. Please click here for ASF’s press release. For additional information, please click here for an article published yesterday in the Wall Street Journal which discusses the repeal of the rule.
We would like to thank ASF’s outside counsel on the matter, Giselle Barth of Sidley Austin LLP, for her outstanding work in producing ASF's request.