Credit Ratings Regulation - Comment Letter - SIFMA - July 5, 2011

From MarketsReformWiki
Jump to: navigation, search
150px-Fidessa.gif


Dodd-Frank Timeline, Removal of Credit Ratings References Under Securities Exchange Act of 1934, SEC
Proposal Date Comment Deadline Final Rule Issue
May 6, 2011 July 5, 2011 December 27, 2013

Removal of Credit Ratings References Under Securities Exchange Act of 1934
July 5, 2011

From the comment letter:

"We believe the Release contains a number of ideas that are helpful and practical in light of the rule changes the Commission is making to comply with Section 939A. We urge the Commission to consider our specific proposals above for refining the Commission‘s proposed approach to the Net Capital Rule haircuts and the Regulation M Exemptions. We believe these suggestions would significantly decrease the extent to which implementation of the Commission‘s mandate under Section 939A would disrupt the market and result in added costs, delay and uncertainty for market participants."

Specifically, SIFMA breaks down its opinions regarding the removal of references to credit ratings in Rule 101 and Rule 102 of Regulation M (market manipulation) and regarding the removal of references to credit ratings in the Broker-Dealer Net Capital Rule. SIFMA suggests that the SEC, through the amendments to the rule, address the fact that a broker-dealer could "reasonably design policies and procedures for determining the credit risk associated with a position in a security that are adapted not only to characteristics of the security itself (as implied by the commentary in the Release) but also to the size of the position and the purpose for which the position is acquired or held by the broker-dealer."

References

MarketsReformWiki Sponsors

McGladrey ADM Investor Services DTCC Fidessa