Regulatory Alerts2022-03-30 | 2022-06583Added · Updated
Removal of References to Credit Ratings From Regulation M
The Securities and Exchange Commission proposes amendments to Regulation M to remove references to credit ratings from Rules 101 and 102 as required by the Dodd-Frank Act. The proposal substitutes alternative credit-worthiness standards, such as probability of default thresholds for nonconvertible securities, and eliminates the investment-grade exception for issuers and selling security holders under Rule 102. Additionally, the Commission requires broker-dealers to maintain written determinations of probability of default to support the new standards under Rule 17a-4(b).
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