Section 939A of the Dodd-Frank Act requires federal agencies to review how existing regulations rely on credit ratings and remove such references from their rules and replace them with standards of creditworthiness as each agency deems appropriate. On July 27, 2011, the SEC unanimously adopted rules to remove references to credit ratings in rules and forms promulgated under the Securities Act of 1933 and the Securities Exchange Act of 1934. The amendments will become effective 30 days after publication in the Federal Register, except for the rescission of Form F-9, which is to become effective December 31, 2012.
Partners Lloyd S. Harmetz and Anna T. Pinedo of Morrison & Foerster will discuss the following:
- Changes to shelf eligibility, including which issuers are likely to be affected and steps to take in advance;
- Alternatives for affected issuers;
- Changes to the research rules;
- Considerations for investment bank compliance personnel;
- Changes to Form F-9 for Canadian issuers;
- ABS related changes; and
- Proposed changes to other securities regulations to remove ratings references.
Speakers:
- Lloyd S. Harmetz
Partner, Morrison and Foerster LLP
- Anna Pinedo
Partner, Morrison and Foerster LLP
PLI will provide CLE credit