Dodd-Frank Timeline, Removal of Certain References to Credit Ratings Under the Securities Exchange Act
| Comment Deadline
|
Final Rule Issue
|
Effective Date
|
| March 28, 2011
|
August 3, 2011
|
September 2, 2011
|
The U.S. Securities and Exchange Commission (SEC) public meeting focused on the issuance of proposed rules under the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding the replacement of references to credit ratings with alternative criteria.
Archived webcast:
Meeting Summary
Topics of Discussion
- Existing regulations' reliance on credit ratings, and removal of such rules when appropriate
- The use of credit ratings to determine "short-form" eligibility
- New short-form test depending on the amount of debt and other non-convertible securities sold within the past three years
Motion to issue proposed rule carries, 5-0
Related Documents
Security Ratings
Speakers
Chairman Mary L. Schapiro, whose statements include:
- An introduction of the first of many proposals to remove references to credit ratings from existing regulation.
- An explanation of short-form eligibility.
- A note that the potential impact of this change on companies and the importance of taking that into consideration when reviewing alternatives.
Commissioner Troy A. Paredes, whose statements include:
- A comparison of this proposal to an amendment considered in 2008, which raised objections from many commenters.
- Concern that a rule change could "frustrate capital formation" by denying companies access to Form S-3, a streamlined short-form registration authorizing a public offering of securities and “off-the-shelf” primary offerings.
- General support for the proposed rule.
Commissioner Kathleen L. Casey, whose statements include:
- Support for the proposed rule.
- Seconding the similarities between the proposed rule and the 2008 proposed amendment.
Commissioner Luis A. Aguilar, whose statements include:
- Questions regarding the minimum threshold substitute of $1 billion, and a request for empirical data supporting it.
- Support for the proposed rule.
References