Order Extending Temporary Conditional Exemption for Nationally Recognized Statistical Rating Organizations From Requirements of Rule 17g-5 Under the Securities Exchange Act of 1934 and Request for Comment, 73137-73139 [2010-29929]
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Federal Register / Vol. 75, No. 228 / Monday, November 29, 2010 / Notices
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Dated: November 22, 2010.
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[FR Doc. 2010–30093 Filed 11–24–10; 4:15 pm]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213.
mstockstill on DSKH9S0YB1PROD with NOTICES
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Rule 701 (17 CFR 230.701) under the
Securities Act of 1933 (‘‘Securities Act’’)
(15 U.S.C. 77a et seq.) provides an
exemption for certain issuers from the
registration requirements of the
Securities Act for limited offerings and
sales of securities issued under
compensatory benefit plans or contracts.
The purpose of Rule 701 is to ensure
that a basic level of information is
available to employees and others when
substantial amounts of securities are
issued in compensatory arrangements.
Approximately 300 companies annually
17:57 Nov 26, 2010
Jkt 223001
Dated: November 22, 2010.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010–29889 Filed 11–26–10; 8:45 am]
BILLING CODE 8011–01–P
Extension:
Rule 701, OMB Control No. 3235–0522,
SEC File No. 270–306.
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rely on the Rule 701 exemption. The
Rule 701 disclosure takes an estimated
2 hours per response to prepare for a
total annual burden of 600 hours. We
estimate that 25% of the 2 hours per
response (0.5 hours) is prepared by the
company for a total annual reporting
burden of 150 hours (0.5 hours per
response × 300 responses).
Written comments are invited on: (a)
Whether this collection of information
is necessary for the proper performance
of the functions of the agency, including
whether the information will have
practical utility; (b) the accuracy of the
agency’s estimate of the burden imposed
by the collection of information; (c)
ways to enhance the quality, utility, and
clarity of the information collected; and
(d) ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
writing within 60 days of this
publication.
Please direct your written comments
to Thomas Bayer, Chief Information
Officer, Securities and Exchange
Commission, C/O Remi Pavlik-Simon,
6432 General Green Way, Alexandria,
Virginia 22312; or send an e-mail to:
PRA_Mailbox@sec.gov.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–63363; File No. S7–04–09]
Order Extending Temporary
Conditional Exemption for Nationally
Recognized Statistical Rating
Organizations From Requirements of
Rule 17g–5 Under the Securities
Exchange Act of 1934 and Request for
Comment
November 23, 2010.
I. Introduction
On May 19, 2010, the Securities and
Exchange Commission (‘‘Commission’’)
conditionally exempted, with respect to
certain credit ratings and until
December 2, 2010, nationally recognized
statistical rating organizations
(‘‘NRSROs’’) from certain requirements
in Rule 17g–5(a)(3) 1 under the
Securities Exchange Act of 1934
1 See
PO 00000
17 CFR 240.17g–5(a)(3).
Frm 00111
Fmt 4703
Sfmt 4703
73137
(‘‘Exchange Act’’), which had a
compliance date of June 2, 2010.2
Pursuant to the Order, an NRSRO is not
required to comply with Rule 17g–
5(a)(3) until December 2, 2010 with
respect to credit ratings where: (1) The
issuer of the structured finance product
is a non-U.S. person; and (2) the NRSRO
has a reasonable basis to conclude that
the structured finance product will be
offered and sold upon issuance, and that
any arranger linked to the structured
finance product will effect transactions
of the structured finance product after
issuance, only in transactions that occur
outside the U.S. (‘‘covered
transactions’’).3 The Commission is
extending the temporary conditional
exemption exempting NRSROs from
complying with Rule 17g–5(a)(3) with
respect to rating covered transactions
until December 2, 2011.
II. Background
Rule 17g–5 identifies, in paragraphs
(b) and (c) of the rule, a series of
conflicts of interest arising from the
business of determining credit ratings.4
Paragraph (a) of Rule 17g–5 5 prohibits
an NRSRO from issuing or maintaining
a credit rating if it is subject to the
conflicts of interest identified in
paragraph (b) of Rule 17g–5 unless the
NRSRO has taken the steps prescribed
in paragraph (a)(1) (i.e., disclosed the
type of conflict of interest in Exhibit 6
to Form NRSRO in accordance with
Section 15E(a)(1)(B)(vi) of the Exchange
Act 6 and Rule 17g–1) 7 and paragraph
(a)(2) (i.e., established and is
maintaining and enforcing written
policies and procedures to address and
manage conflicts of interest in
accordance with Section 15E(h) of the
Exchange Act).8 Paragraph (c) of Rule
17g–5 specifically prohibits seven types
of conflicts of interest. Consequently, an
NRSRO is prohibited from issuing or
maintaining a credit rating when it is
subject to these conflicts regardless of
whether it had disclosed them and
established procedures reasonably
designed to address them.
In December 2009, the Commission
adopted subparagraph (a)(3) to Rule
17g–5. This provision requires an
NRSRO that is hired by an arranger to
determine an initial credit rating for a
structured finance product to take
2 See Securities Exchange Act Release No. 62120
(May 19, 2010), 75 FR 28825 (May 24, 2010)
(‘‘Order’’).
3 See id. at 28827–28 (setting forth conditions of
relief).
4 17 CFR 240.17g–5(b) and (c).
5 17 CFR 240.17g–5(a).
6 15 U.S.C. 78o–7(a)(1)(B)(vi).
7 17 CFR 240.17g–1.
8 15 U.S.C. 78o–7(h).
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certain steps designed to allow an
NRSRO that is not hired by the arranger
to nonetheless determine an initial
credit rating—and subsequently monitor
that credit rating—for the structured
finance product.9 In particular, under
Rule 17g–5(a)(3), an NRSRO is
prohibited from issuing or maintaining
a credit rating when it is subject to the
conflict of interest identified in
paragraph (b)(9) of Rule 17g–5 (i.e.,
being hired by an arranger to determine
a credit rating for a structured finance
product) 10 unless it has taken the steps
prescribed in paragraphs (a)(1) and (2)
of Rule 17g–5 (discussed above) and the
steps prescribed in new paragraph (a)(3)
of Rule 17g–5.11 Rule 17g–5(a)(3),
among other things, requires that the
NRSRO must:
• Maintain on a password-protected
Internet Web site a list of each
structured finance product for which it
currently is in the process of
determining an initial credit rating in
chronological order and identifying the
type of structured finance product, the
name of the issuer, the date the rating
process was initiated, and the Internet
Web site address where the arranger
represents the information provided to
the hired NRSRO can be accessed by
other NRSROs;
• Provide free and unlimited access
to such password-protected Internet
Web site during the applicable calendar
year to any NRSRO that provides it with
a copy of the certification described in
paragraph (e) of Rule 17g–5 that covers
that calendar year; 12 and
9 See 17 CFR 240.17g–5(a)(3); see also Securities
Exchange Act Release No. 61050 (November 23,
2009), 74 FR 63832 (‘‘Adopting Release’’) at 63844–
45.
10 Paragraph (b)(9) of Rule 17g–5 identifies the
following conflict of interest: issuing or maintaining
a credit rating for a security or money market
instrument issued by an asset pool or as part of any
asset-backed or mortgage-backed securities
transaction that was paid for by the issuer, sponsor,
or underwriter of the security or money market
instrument. 17 CFR 240.17g–5(b)(9).
11 17 CFR 240.17g–5(a)(3).
12 Paragraph (e) of Rule 17g–5 requires that an
NRSRO seeking to access the hired NRSRO’s
Internet website during the applicable calendar year
must furnish the Commission with the following
certification:
The undersigned hereby certifies that it will
access the Internet Web sites described in 17 CFR
240.17g–5(a)(3) solely for the purpose of
determining or monitoring credit ratings. Further,
the undersigned certifies that it will keep the
information it accesses pursuant to 17 CFR
240.17g–5(a)(3) confidential and treat it as material
nonpublic information subject to its written policies
and procedures established, maintained, and
enforced pursuant to section 15E(g)(1) of the Act (15
U.S.C. 78o–7(g)(1)) and 17 CFR 240.17g–4. Further,
the undersigned certifies that it will determine and
maintain credit ratings for at least 10% of the issued
securities and money market instruments for which
it accesses information pursuant to 17 CFR
240.17g–5(a)(3)(iii), if it accesses such information
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17:57 Nov 26, 2010
Jkt 223001
• Obtain from the arranger a written
representation that can reasonably be
relied upon that the arranger will,
among other things, disclose on a
password-protected Internet web site
the information it provides to the hired
NRSRO to determine the initial credit
rating (and monitor that credit rating)
and provide access to the web site to an
NRSRO that provides it with a copy of
the certification described in paragraph
(e) Rule 17g–5.13
The Commission stated in the
Adopting Release that subparagraph
Rule 17g–5(a)(3) is designed to address
for 10 or more issued securities or money market
instruments in the calendar year covered by the
certification. Further, the undersigned certifies one
of the following as applicable: (1) In the most recent
calendar year during which it accessed information
pursuant to 17 CFR 240.17g–5(a)(3), the
undersigned accessed information for [Insert
Number] issued securities and money market
instruments through Internet Web sites described in
17 CFR 240.17g–5(a)(3) and determined and
maintained credit ratings for [Insert Number] of
such securities and money market instruments; or
(2) The undersigned previously has not accessed
information pursuant to 17 CFR 240.17g–5(a)(3) 10
or more times during the most recently ended
calendar year.
13 In particular, under paragraph (a)(3)(iii) of Rule
17g–5, the arranger must represent to the hired
NRSRO that it will:
(1) Maintain the information described in
paragraphs (a)(3)(iii)(C) and (a)(3)(iii)(D) of Rule
17g–5 available at an identified password-protected
Internet Web site that presents the information in
a manner indicating which information currently
should be relied on to determine or monitor the
credit rating;
(2) Provide access to such password-protected
Internet Web site during the applicable calendar
year to any NRSRO that provides it with a copy of
the certification described in paragraph (e) of Rule
17g–5 that covers that calendar year, provided that
such certification indicates that the nationally
recognized statistical rating organization providing
the certification either: (i) Determined and
maintained credit ratings for at least 10% of the
issued securities and money market instruments for
which it accessed information pursuant to
paragraph (a)(3)(iii) of Rule 17g–5 in the calendar
year prior to the year covered by the certification,
if it accessed such information for 10 or more
issued securities or money market instruments; or
(ii) has not accessed information pursuant to
paragraph (a)(3) of Rule 17g–5 10 or more times
during the most recently ended calendar year.
(3) Post on such password-protected Internet Web
site all information the arranger provides to the
NRSRO, or contracts with a third party to provide
to the NRSRO, for the purpose of determining the
initial credit rating for the security or money market
instrument, including information about the
characteristics of the assets underlying or
referenced by the security or money market
instrument, and the legal structure of the security
or money market instrument, at the same time such
information is provided to the NRSRO; and
(4) Post on such password-protected Internet Web
site all information the arranger provides to the
NRSRO, or contracts with a third party to provide
to the NRSRO, for the purpose of undertaking credit
rating surveillance on the security or money market
instrument, including information about the
characteristics and performance of the assets
underlying or referenced by the security or money
market instrument at the same time such
information is provided to the NRSRO.
PO 00000
Frm 00112
Fmt 4703
Sfmt 4703
conflicts of interest and improve the
quality of credit ratings for structured
finance products by making it possible
for more NRSROs to rate structured
finance products.14 For example, the
Commission noted that when an NRSRO
is hired to rate a structured finance
product, some of the information it
relies on to determine the rating is
generally not made public.15 As a result,
structured finance products frequently
are issued with ratings from only the
one or two NRSROs that have been
hired by the arranger, with the attendant
conflict of interest that creates.16 The
Commission stated that subparagraph
Rule 17g–5(a)(3) was designed to
increase the number of credit ratings
extant for a given structured finance
product and, in particular, to promote
the issuance of credit ratings by
NRSROs that are not hired by
arrangers.17 The Commission’s goal in
adopting the rule was to provide users
of credit ratings with more views on the
creditworthiness of structured finance
products.18 In addition, the Commission
stated that Rule 17g–5(a)(3) was
designed to reduce the ability of
arrangers to obtain better than
warranted ratings by exerting influence
over NRSROs hired to determine credit
ratings for structured finance
products.19 Specifically, by opening up
the rating process to more NRSROs, the
Commission intended to make it easier
for the hired NRSRO to resist such
pressure by increasing the likelihood
that any steps taken to inappropriately
favor the arranger could be exposed to
the market through the credit ratings
issued by other NRSROs.20
Rule 17g–5(a)(3) became effective on
February 2, 2010, and the compliance
date for Rule 17g–5(a)(3) was June 2,
2010.
III. Extension of Conditional
Temporary Extension
In the Order, the Commission
requested comment generally, but also
on a number of specific issues.21 The
Commission received six comments in
response to this solicitation of
comment.22 The commenters continue
14 Adopting
Release at 63844.
15 Id.
16 Id.
17 Id.
18 Id.
19 Id.
20 Id.
21 See
Order, supra note 2, at 28828.
from Masamichi Kono, Vice
Commissioner for International Affairs, Financial
Services Agency, Japan, to Elizabeth Murphy,
Secretary, Commission, dated Nov. 12, 2010 (‘‘Japan
FSA Letter’’); Letter from Masaru Ono, Executive
Director, Securitization Forum of Japan, to
Elizabeth Murphy, Secretary, Commission, dated
22 Letter
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Federal Register / Vol. 75, No. 228 / Monday, November 29, 2010 / Notices
to express concern that the
extraterritorial application of Rule 17g–
5(a)(3) could, in the commenter’s view,
among other things, disrupt local
securitization markets,23 inhibit the
ability of local firms to raise capital,24
and conflict with local laws.25 Several
commenters also requested that the
conditional temporary exemption be
extended or made permanent.26 Given
the continued concerns about potential
disruptions of local securitization
markets, and because the Commission’s
consideration of the issues raised will
benefit from additional time to engage
in further dialogue with interested
parties and to monitor market and
regulatory developments, the
Commission believes extending the
conditional temporary exemption until
December 2, 2011 is necessary or
appropriate in the public interest, and is
consistent with the protection of
investors.
IV. Request for Comment
The Commission believes that it
would be useful to continue to provide
interested parties opportunity to
comment. Comments may be submitted
by any of the following methods:
Electronic Comments
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• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/exorders.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number S7–04–09 on the subject line;
or
Nov. 12, 2010 (‘‘SFJ Letter’’); Letter from Rick
Watson, Managing Director, Association for
Financial Markets in Europe/European
Securitisation Forum, to Elizabeth Murphy,
Secretary, Commission, dated Nov. 11, 2010
(‘‘AFME Letter’’); Letter from Jack Rando, Director,
Capital Markets, Investment Industry Association of
Canada, to Randall Roy, Assistant Director,
Division, Commission, dated Sep. 22, 2010 (‘‘IIAC
Letter’’); Letter from Christopher Dalton, Chief
Executive Officer, Australian Securitisation Forum,
to Randall Roy, Assistant Director, Division,
Commission, dated Jun. 27, 2010 (‘‘AuSF Letter’’);
Letter from Takefumi Emori, Managing Director,
Japan Credit Rating Agency, Ltd. (‘‘JCR’’) to
Elizabeth Murphy, Secretary, Commission, dated
Jun. 25, 2010 (‘‘JCR Letter’’).
23 See Japan FSA Letter; SFJ Letter; AFME Letter;
JCR Letter, AuSF Letter.
24 See AFME Letter; JCR Letter; AuSF Letter.
25 See Japan FSA Letter; AFME Letter; JCR Letter;
AuSF Letter; IIAC Letter. With respect to local laws,
we note that the European Commission in recent
months has issued a relevant proposal for
amendments to the European Union Regulation on
Credit Ratings. See ‘‘Regulation of the European
Parliament and of the Counsel on amending
Regulation (EC) No 1060/2009 on credit rating
agencies’’ (available at https://ec.europa.eu/
internal_market/securities/docs/agencies/
100602_proposal_en.pdf).
26 See Japan FSA Letter; SFJ Letter; AFME Letter;
JCR Letter.
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17:57 Nov 26, 2010
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73139
• Use the Federal eRulemaking Portal
(https://www.regulations.gov). Follow the
instructions for submitting comments.
By the Commission.
Elizabeth M. Murphy,
Secretary.
Paper Comments
[FR Doc. 2010–29929 Filed 11–26–10; 8:45 am]
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F St., NE., Washington, DC 20549–
1090.
BILLING CODE 8011–01–P
All submissions should refer to File
Number S7–04–09. This file number
should be included on the subject line
if e-mail is used. To help us process and
review your comments more efficiently,
please use only one method. The
Commission will post all comments on
the Commission’s Internet website
(https://www.sec.gov/rules/
exorders.shtml). Comments are also
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F St. NE.,
Washington, DC 20549 on official
business days between the hours of 10
a.m. and 3 p.m. All comments received
will be posted without change; the
Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly.
Sunshine Act Meeting
V. Conclusion
For the foregoing reasons, the
Commission believes it would be
necessary or appropriate in the public
interest and consistent with the
protection of investors to extend the
conditional temporary exemption
exempting NRSROs from complying
with Rule 17g–5(a)(3) with respect to
rating covered transactions until
December 2, 2011.
Accordingly
It is hereby ordered, pursuant to
Section 36 of the Exchange Act, that a
nationally recognized statistical rating
organization is exempt until December
2, 2011 from the requirements in Rule
17g–5(a)(3) (17 CFR 240.17g–5(a)(3)) for
credit ratings where:
(1) The issuer of the security or
money market instrument is not a U.S.
person (as defined under Securities Act
Rule 902(k)); and
(2) The nationally recognized
statistical rating organization has a
reasonable basis to conclude that the
structured finance product will be
offered and sold upon issuance, and that
any arranger linked to the structured
finance product will effect transactions
of the structured finance product after
issuance, only in transactions that occur
outside the U.S.
PO 00000
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Fmt 4703
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SECURITIES AND EXCHANGE
COMMISSION
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission will hold a Closed Meeting
on Thursday, December 2, 2010 at 2
p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meeting. Certain
staff members who have an interest in
the matters also may be present.
The General Counsel of the
Commission, or his designee, has
certified that, in his opinion, one or
more of the exemptions set forth in 5
U.S.C. 552b(c)(3), (5), (7), 9(B) and (10)
and 17 CFR 200.402(a)(3), (5), (7), 9(ii)
and (10), permit consideration of the
scheduled matters at the Closed
Meeting.
Commissioner Casey, as duty officer,
voted to consider the items listed for the
Closed Meeting in a closed session.
The subject matter of the Closed
Meeting scheduled for Thursday,
December 2, 2010 will be:
Institution and settlement of
injunctive actions;
Institution and settlement of
administrative proceedings;
An adjudicatory matter; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact:
The Office of the Secretary at (202)
551–5400.
Dated: November 24, 2010.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010–30055 Filed 11–24–10; 11:15 am]
BILLING CODE 8011–01–P
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Agencies
[Federal Register Volume 75, Number 228 (Monday, November 29, 2010)]
[Notices]
[Pages 73137-73139]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-29929]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-63363; File No. S7-04-09]
Order Extending Temporary Conditional Exemption for Nationally
Recognized Statistical Rating Organizations From Requirements of Rule
17g-5 Under the Securities Exchange Act of 1934 and Request for Comment
November 23, 2010.
I. Introduction
On May 19, 2010, the Securities and Exchange Commission
(``Commission'') conditionally exempted, with respect to certain credit
ratings and until December 2, 2010, nationally recognized statistical
rating organizations (``NRSROs'') from certain requirements in Rule
17g-5(a)(3) \1\ under the Securities Exchange Act of 1934 (``Exchange
Act''), which had a compliance date of June 2, 2010.\2\ Pursuant to the
Order, an NRSRO is not required to comply with Rule 17g-5(a)(3) until
December 2, 2010 with respect to credit ratings where: (1) The issuer
of the structured finance product is a non-U.S. person; and (2) the
NRSRO has a reasonable basis to conclude that the structured finance
product will be offered and sold upon issuance, and that any arranger
linked to the structured finance product will effect transactions of
the structured finance product after issuance, only in transactions
that occur outside the U.S. (``covered transactions'').\3\ The
Commission is extending the temporary conditional exemption exempting
NRSROs from complying with Rule 17g-5(a)(3) with respect to rating
covered transactions until December 2, 2011.
---------------------------------------------------------------------------
\1\ See 17 CFR 240.17g-5(a)(3).
\2\ See Securities Exchange Act Release No. 62120 (May 19,
2010), 75 FR 28825 (May 24, 2010) (``Order'').
\3\ See id. at 28827-28 (setting forth conditions of relief).
---------------------------------------------------------------------------
II. Background
Rule 17g-5 identifies, in paragraphs (b) and (c) of the rule, a
series of conflicts of interest arising from the business of
determining credit ratings.\4\ Paragraph (a) of Rule 17g-5 \5\
prohibits an NRSRO from issuing or maintaining a credit rating if it is
subject to the conflicts of interest identified in paragraph (b) of
Rule 17g-5 unless the NRSRO has taken the steps prescribed in paragraph
(a)(1) (i.e., disclosed the type of conflict of interest in Exhibit 6
to Form NRSRO in accordance with Section 15E(a)(1)(B)(vi) of the
Exchange Act \6\ and Rule 17g-1) \7\ and paragraph (a)(2) (i.e.,
established and is maintaining and enforcing written policies and
procedures to address and manage conflicts of interest in accordance
with Section 15E(h) of the Exchange Act).\8\ Paragraph (c) of Rule 17g-
5 specifically prohibits seven types of conflicts of interest.
Consequently, an NRSRO is prohibited from issuing or maintaining a
credit rating when it is subject to these conflicts regardless of
whether it had disclosed them and established procedures reasonably
designed to address them.
---------------------------------------------------------------------------
\4\ 17 CFR 240.17g-5(b) and (c).
\5\ 17 CFR 240.17g-5(a).
\6\ 15 U.S.C. 78o-7(a)(1)(B)(vi).
\7\ 17 CFR 240.17g-1.
\8\ 15 U.S.C. 78o-7(h).
---------------------------------------------------------------------------
In December 2009, the Commission adopted subparagraph (a)(3) to
Rule 17g-5. This provision requires an NRSRO that is hired by an
arranger to determine an initial credit rating for a structured finance
product to take
[[Page 73138]]
certain steps designed to allow an NRSRO that is not hired by the
arranger to nonetheless determine an initial credit rating--and
subsequently monitor that credit rating--for the structured finance
product.\9\ In particular, under Rule 17g-5(a)(3), an NRSRO is
prohibited from issuing or maintaining a credit rating when it is
subject to the conflict of interest identified in paragraph (b)(9) of
Rule 17g-5 (i.e., being hired by an arranger to determine a credit
rating for a structured finance product) \10\ unless it has taken the
steps prescribed in paragraphs (a)(1) and (2) of Rule 17g-5 (discussed
above) and the steps prescribed in new paragraph (a)(3) of Rule 17g-
5.\11\ Rule 17g-5(a)(3), among other things, requires that the NRSRO
must:
---------------------------------------------------------------------------
\9\ See 17 CFR 240.17g-5(a)(3); see also Securities Exchange Act
Release No. 61050 (November 23, 2009), 74 FR 63832 (``Adopting
Release'') at 63844-45.
\10\ Paragraph (b)(9) of Rule 17g-5 identifies the following
conflict of interest: issuing or maintaining a credit rating for a
security or money market instrument issued by an asset pool or as
part of any asset-backed or mortgage-backed securities transaction
that was paid for by the issuer, sponsor, or underwriter of the
security or money market instrument. 17 CFR 240.17g-5(b)(9).
\11\ 17 CFR 240.17g-5(a)(3).
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Maintain on a password-protected Internet Web site a list
of each structured finance product for which it currently is in the
process of determining an initial credit rating in chronological order
and identifying the type of structured finance product, the name of the
issuer, the date the rating process was initiated, and the Internet Web
site address where the arranger represents the information provided to
the hired NRSRO can be accessed by other NRSROs;
Provide free and unlimited access to such password-
protected Internet Web site during the applicable calendar year to any
NRSRO that provides it with a copy of the certification described in
paragraph (e) of Rule 17g-5 that covers that calendar year; \12\ and
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\12\ Paragraph (e) of Rule 17g-5 requires that an NRSRO seeking
to access the hired NRSRO's Internet website during the applicable
calendar year must furnish the Commission with the following
certification:
The undersigned hereby certifies that it will access the
Internet Web sites described in 17 CFR 240.17g-5(a)(3) solely for
the purpose of determining or monitoring credit ratings. Further,
the undersigned certifies that it will keep the information it
accesses pursuant to 17 CFR 240.17g-5(a)(3) confidential and treat
it as material nonpublic information subject to its written policies
and procedures established, maintained, and enforced pursuant to
section 15E(g)(1) of the Act (15 U.S.C. 78o-7(g)(1)) and 17 CFR
240.17g-4. Further, the undersigned certifies that it will determine
and maintain credit ratings for at least 10% of the issued
securities and money market instruments for which it accesses
information pursuant to 17 CFR 240.17g-5(a)(3)(iii), if it accesses
such information for 10 or more issued securities or money market
instruments in the calendar year covered by the certification.
Further, the undersigned certifies one of the following as
applicable: (1) In the most recent calendar year during which it
accessed information pursuant to 17 CFR 240.17g-5(a)(3), the
undersigned accessed information for [Insert Number] issued
securities and money market instruments through Internet Web sites
described in 17 CFR 240.17g-5(a)(3) and determined and maintained
credit ratings for [Insert Number] of such securities and money
market instruments; or (2) The undersigned previously has not
accessed information pursuant to 17 CFR 240.17g-5(a)(3) 10 or more
times during the most recently ended calendar year.
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Obtain from the arranger a written representation that can
reasonably be relied upon that the arranger will, among other things,
disclose on a password-protected Internet web site the information it
provides to the hired NRSRO to determine the initial credit rating (and
monitor that credit rating) and provide access to the web site to an
NRSRO that provides it with a copy of the certification described in
paragraph (e) Rule 17g-5.\13\
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\13\ In particular, under paragraph (a)(3)(iii) of Rule 17g-5,
the arranger must represent to the hired NRSRO that it will:
(1) Maintain the information described in paragraphs
(a)(3)(iii)(C) and (a)(3)(iii)(D) of Rule 17g-5 available at an
identified password-protected Internet Web site that presents the
information in a manner indicating which information currently
should be relied on to determine or monitor the credit rating;
(2) Provide access to such password-protected Internet Web site
during the applicable calendar year to any NRSRO that provides it
with a copy of the certification described in paragraph (e) of Rule
17g-5 that covers that calendar year, provided that such
certification indicates that the nationally recognized statistical
rating organization providing the certification either: (i)
Determined and maintained credit ratings for at least 10% of the
issued securities and money market instruments for which it accessed
information pursuant to paragraph (a)(3)(iii) of Rule 17g-5 in the
calendar year prior to the year covered by the certification, if it
accessed such information for 10 or more issued securities or money
market instruments; or (ii) has not accessed information pursuant to
paragraph (a)(3) of Rule 17g-5 10 or more times during the most
recently ended calendar year.
(3) Post on such password-protected Internet Web site all
information the arranger provides to the NRSRO, or contracts with a
third party to provide to the NRSRO, for the purpose of determining
the initial credit rating for the security or money market
instrument, including information about the characteristics of the
assets underlying or referenced by the security or money market
instrument, and the legal structure of the security or money market
instrument, at the same time such information is provided to the
NRSRO; and
(4) Post on such password-protected Internet Web site all
information the arranger provides to the NRSRO, or contracts with a
third party to provide to the NRSRO, for the purpose of undertaking
credit rating surveillance on the security or money market
instrument, including information about the characteristics and
performance of the assets underlying or referenced by the security
or money market instrument at the same time such information is
provided to the NRSRO.
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The Commission stated in the Adopting Release that subparagraph
Rule 17g-5(a)(3) is designed to address conflicts of interest and
improve the quality of credit ratings for structured finance products
by making it possible for more NRSROs to rate structured finance
products.\14\ For example, the Commission noted that when an NRSRO is
hired to rate a structured finance product, some of the information it
relies on to determine the rating is generally not made public.\15\ As
a result, structured finance products frequently are issued with
ratings from only the one or two NRSROs that have been hired by the
arranger, with the attendant conflict of interest that creates.\16\ The
Commission stated that subparagraph Rule 17g-5(a)(3) was designed to
increase the number of credit ratings extant for a given structured
finance product and, in particular, to promote the issuance of credit
ratings by NRSROs that are not hired by arrangers.\17\ The Commission's
goal in adopting the rule was to provide users of credit ratings with
more views on the creditworthiness of structured finance products.\18\
In addition, the Commission stated that Rule 17g-5(a)(3) was designed
to reduce the ability of arrangers to obtain better than warranted
ratings by exerting influence over NRSROs hired to determine credit
ratings for structured finance products.\19\ Specifically, by opening
up the rating process to more NRSROs, the Commission intended to make
it easier for the hired NRSRO to resist such pressure by increasing the
likelihood that any steps taken to inappropriately favor the arranger
could be exposed to the market through the credit ratings issued by
other NRSROs.\20\
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\14\ Adopting Release at 63844.
\15\ Id.
\16\ Id.
\17\ Id.
\18\ Id.
\19\ Id.
\20\ Id.
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Rule 17g-5(a)(3) became effective on February 2, 2010, and the
compliance date for Rule 17g-5(a)(3) was June 2, 2010.
III. Extension of Conditional Temporary Extension
In the Order, the Commission requested comment generally, but also
on a number of specific issues.\21\ The Commission received six
comments in response to this solicitation of comment.\22\ The
commenters continue
[[Page 73139]]
to express concern that the extraterritorial application of Rule 17g-
5(a)(3) could, in the commenter's view, among other things, disrupt
local securitization markets,\23\ inhibit the ability of local firms to
raise capital,\24\ and conflict with local laws.\25\ Several commenters
also requested that the conditional temporary exemption be extended or
made permanent.\26\ Given the continued concerns about potential
disruptions of local securitization markets, and because the
Commission's consideration of the issues raised will benefit from
additional time to engage in further dialogue with interested parties
and to monitor market and regulatory developments, the Commission
believes extending the conditional temporary exemption until December
2, 2011 is necessary or appropriate in the public interest, and is
consistent with the protection of investors.
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\21\ See Order, supra note 2, at 28828.
\22\ Letter from Masamichi Kono, Vice Commissioner for
International Affairs, Financial Services Agency, Japan, to
Elizabeth Murphy, Secretary, Commission, dated Nov. 12, 2010
(``Japan FSA Letter''); Letter from Masaru Ono, Executive Director,
Securitization Forum of Japan, to Elizabeth Murphy, Secretary,
Commission, dated Nov. 12, 2010 (``SFJ Letter''); Letter from Rick
Watson, Managing Director, Association for Financial Markets in
Europe/European Securitisation Forum, to Elizabeth Murphy,
Secretary, Commission, dated Nov. 11, 2010 (``AFME Letter''); Letter
from Jack Rando, Director, Capital Markets, Investment Industry
Association of Canada, to Randall Roy, Assistant Director, Division,
Commission, dated Sep. 22, 2010 (``IIAC Letter''); Letter from
Christopher Dalton, Chief Executive Officer, Australian
Securitisation Forum, to Randall Roy, Assistant Director, Division,
Commission, dated Jun. 27, 2010 (``AuSF Letter''); Letter from
Takefumi Emori, Managing Director, Japan Credit Rating Agency, Ltd.
(``JCR'') to Elizabeth Murphy, Secretary, Commission, dated Jun. 25,
2010 (``JCR Letter'').
\23\ See Japan FSA Letter; SFJ Letter; AFME Letter; JCR Letter,
AuSF Letter.
\24\ See AFME Letter; JCR Letter; AuSF Letter.
\25\ See Japan FSA Letter; AFME Letter; JCR Letter; AuSF Letter;
IIAC Letter. With respect to local laws, we note that the European
Commission in recent months has issued a relevant proposal for
amendments to the European Union Regulation on Credit Ratings. See
``Regulation of the European Parliament and of the Counsel on
amending Regulation (EC) No 1060/2009 on credit rating agencies''
(available at https://ec.europa.eu/internal_market/securities/docs/agencies/100602_proposal_en.pdf).
\26\ See Japan FSA Letter; SFJ Letter; AFME Letter; JCR Letter.
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IV. Request for Comment
The Commission believes that it would be useful to continue to
provide interested parties opportunity to comment. Comments may be
submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/exorders.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number S7-04-09 on the subject line; or
Use the Federal eRulemaking Portal (https://www.regulations.gov). Follow the instructions for submitting comments.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F St., NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number S7-04-09. This file number
should be included on the subject line if e-mail is used. To help us
process and review your comments more efficiently, please use only one
method. The Commission will post all comments on the Commission's
Internet website (https://www.sec.gov/rules/exorders.shtml). Comments
are also available for website viewing and printing in the Commission's
Public Reference Room, 100 F St. NE., Washington, DC 20549 on official
business days between the hours of 10 a.m. and 3 p.m. All comments
received will be posted without change; the Commission does not edit
personal identifying information from submissions. You should submit
only information that you wish to make available publicly.
V. Conclusion
For the foregoing reasons, the Commission believes it would be
necessary or appropriate in the public interest and consistent with the
protection of investors to extend the conditional temporary exemption
exempting NRSROs from complying with Rule 17g-5(a)(3) with respect to
rating covered transactions until December 2, 2011.
Accordingly
It is hereby ordered, pursuant to Section 36 of the Exchange Act,
that a nationally recognized statistical rating organization is exempt
until December 2, 2011 from the requirements in Rule 17g-5(a)(3) (17
CFR 240.17g-5(a)(3)) for credit ratings where:
(1) The issuer of the security or money market instrument is not a
U.S. person (as defined under Securities Act Rule 902(k)); and
(2) The nationally recognized statistical rating organization has a
reasonable basis to conclude that the structured finance product will
be offered and sold upon issuance, and that any arranger linked to the
structured finance product will effect transactions of the structured
finance product after issuance, only in transactions that occur outside
the U.S.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010-29929 Filed 11-26-10; 8:45 am]
BILLING CODE 8011-01-P