Credit Ratings Regulation - Comment Letter - Boeing - March 25, 2011

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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

Security Ratings
March 25, 2011

Boeing Capital Corporation (BCC) offers the following summary of comments:

  • "BCC believes that the proposal should be revised to make Form S-3 also available to a majority owned subsidiary of a well-known seasoned issuer (WKSI) if the subsidiary has at least $1 billion in assets or $1 billion in public debt securities outstanding. Each of these criteria is a convincing index of a widely followed issuer; and
  • The parent guarantee eligibility provisions are not an appropriate alternative for WKSI subsidiaries that would not qualify under the proposal."

BCC states that the $1 billion test threshold is not an appropriate replacement for the current rule that allows companies with less than $75 million in common equity held by non-affiliates to register the sale of non-convertible investment grade debt securities. This alternative, according to the letter, will exclude some "widely followed issuers of public debt" and would put at risk the any effective cost and flexibility structures that exist in this regard.



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