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, 70261-70263 [2014-27846]
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All submissions should refer to File
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2014–11 and should be submitted on or
before December 16, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.10
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–27841 Filed 11–24–14; 8:45 am]
BILLING CODE 8011–01–P
10 17
CFR 200.30–3(a)(12).
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73649; 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 19, 2014.
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 On November 23, 2010,
the Commission extended the
conditional temporary exemption until
December 2, 2011.4 On November 16,
2011, the Commission extended the
conditional temporary exemption until
December 2, 2012.5 On November 26,
2012, the Commission extended the
conditional temporary exemption until
December 2, 2013.6 On November 22,
2013, the Commission extended the
conditional temporary exemption until
December 2, 2014.7 The Commission is
1 See
17 CFR 240.17g–5(a)(3).
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 See Exchange Act Release No. 63363 (Nov. 23,
2010), 75 FR 73137 (Nov. 29, 2010) (‘‘First
Extension Order’’).
5 See Exchange Act Release No. 65765 (Nov. 16,
2011), 76 FR 72227 (Nov. 22, 2011) (‘‘Second
Extension Order’’).
6 See Exchange Act Release No. 34–68286 (Nov.
26, 2012), 77 FR 71201 (Nov. 29, 2012) (‘‘Third
Extension Order’’).
7 See Exchange Act Release No. 34–70919 (Nov.
22, 2013), 78 FR 70984 (Nov. 27, 2013) (‘‘Fourth
Extension Order’’).
2 See
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70261
extending the temporary conditional
exemption exempting NRSROs from
complying with Rule 17g–5(a)(3) with
respect to rating covered transactions
until December 2, 2015.
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.8
Paragraph (a) of Rule 17g–5 9 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 10 and Rule 17g–1) 11 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).12 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
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.13 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) 14 unless it has taken the steps
8 17
CFR 240.17g–5(b) and (c).
CFR 240.17g–5(a).
10 15 U.S.C. 78o–7(a)(1)(B)(vi).
11 17 CFR 240.17g–1.
12 15 U.S.C. 78o–7(h).
13 See 17 CFR 240.17g–5(a)(3); see also Exchange
Act Release No. 61050 (Nov. 23, 2009), 74 FR 63832
(Dec. 4, 2009) (‘‘Adopting Release’’) at 63844–45.
14 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
9 17
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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–5.15 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; 16 and
• 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)
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).
15 17 CFR 240.17g–5(a)(3).
16 Paragraph (e) of Rule 17g–5 requires that an
NRSRO seeking to access the hired NRSRO’s
Internet Web site 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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14:41 Nov 24, 2014
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and provide access to the Web site to an
NRSRO that provides it with a copy of
the certification described in paragraph
(e) of Rule 17g–5.17
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.18 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.19 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.20 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
17 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.
18 Adopting Release at 63844.
19 Id.
20 Id.
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Fmt 4703
Sfmt 4703
the issuance of credit ratings by
NRSROs that are not hired by
arrangers.21 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.22 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.23 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.24
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.25 The
Commission received six comment
letters in response to this solicitation of
comment.26 The commenters expressed
concern that the extraterritorial
application of Rule 17g–5(a)(3) could, in
the commenter’s view, among other
things, disrupt local securitization
markets,27 inhibit the ability of local
firms to raise capital,28 and conflict with
local laws.29 Several commenters also
21 Id.
22 Id.
23 Id.
24 Id.
25 See
Order at 28828.
from Masamichi Kono, Vice
Commissioner for International Affairs, Financial
Services Agency, Japan, dated Nov. 12, 2010
(‘‘Japan FSA Letter’’); Letter from Masaru Ono,
Executive Director, Securitization Forum of Japan,
dated Nov. 12, 2010 (‘‘SFJ Letter’’); Letter from Rick
Watson, Managing Director, Association for
Financial Markets in Europe/European
Securitisation Forum, dated Nov. 11, 2010 (‘‘AFME
Letter’’); Letter from Jack Rando, Director, Capital
Markets, Investment Industry Association of
Canada, dated Sep. 22, 2010 (‘‘IIAC Letter’’); Letter
from Christopher Dalton, Chief Executive Officer,
Australian Securitisation Forum, dated Jun. 27,
2010 (‘‘AuSF Letter’’); Letter from Takefumi Emori,
Managing Director, Japan Credit Rating Agency,
Ltd. (‘‘JCR’’), dated Jun. 25, 2010 (‘‘JCR Letter’’).
27 See Japan FSA Letter; SFJ Letter; AFME Letter;
JCR Letter; AuSF Letter.
28 See AFME Letter; JCR Letter; AuSF Letter.
29 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
26 Letter
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Federal Register / Vol. 79, No. 227 / Tuesday, November 25, 2014 / Notices
wreier-aviles on DSK4TPTVN1PROD with NOTICES
requested that the conditional
temporary exemption be extended or
made permanent.30 The First Extension
Order again solicited public comment
on issues raised in connection with the
extra-territorial application of Rule 17g–
5(a)(3).31 One commenter requested that
the Order be made permanent, citing
many of the same reasons set forth in
prior comment letters.32 The Second
Extension Order again solicited public
comment on issues raised in connection
with the extra-territorial application of
Rule 17g–5(a)(3).33 Commenters
supported the exemption regarding the
extra-territorial application of the
Rule,34 with one of those commenters
again requesting that the Order be made
permanent.35 The Third Extension
Order again solicited public comment
on issues raised in connection with the
extra-territorial application of Rule 17g–
5(a)(3). No comments were received.
The Fourth Extension Order again
solicited public comment on issues
raised in connection with the extraterritorial application of Rule 17g–
5(a)(3). One comment was received and
the commenter supported the
exemption regarding the extra-territorial
application of the Rule.36
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, 2015 is
necessary or appropriate in the public
interest, and is consistent with the
protection of investors.
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).
30 See Japan FSA Letter; SFJ Letter; AFME Letter;
JCR Letter.
31 See Letter from Tom Deutsch, Executive
Director, American Securitization Forum, and Chris
Dalton, Chief Executive Officer, Australian
Securitization Forum, dated Aug. 9, 2011 (‘‘ASF/
AuSF Letter 1’’); Letter from Jack Rando, Director,
Capital Markets, Investment Industry Association of
Canada, dated Nov. 2, 2011 (‘‘IIAC Letter 2’’).
32 See ASF/AuSF Letter 1.
33 Letter from Chris Barnard to the Commission,
dated Nov. 23, 2011 (‘‘Barnard Letter’’); Letter from
Tom Deutsch, Executive Director, American
Securitization Forum and Chris Dalton, Chief
Executive Officer, Australian Securitisation Forum,
dated Aug. 28, 2012 (‘‘ASF/AuSF Letter 2’’).
34 See Barnard Letter; ASF/AuSF Letter 2.
35 See ASF/AuSF Letter 2.
36 See Letter from Chris Barnard to the
Commission, dated Nov. 26, 2013.
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14:41 Nov 24, 2014
Jkt 235001
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 email 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 Brent J. Fields, 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 email 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 Web site
(https://www.sec.gov/rules/
exorders.shtml). Comments are also
available for Web site 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, 2015.
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, 2015 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
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Sfmt 4703
70263
(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.
Brent J. Fields,
Secretary.
[FR Doc. 2014–27846 Filed 11–24–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[File No. 500–1]
In the Matter of Bravo Enterprises Ltd.;
Immunotech Laboratories, Inc.; Myriad
Interactive Media, Inc.; Wholehealth
Products, Inc.; Order of Suspension of
Trading
November 20, 2014.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of the issuers
listed below.
1. Bravo Enterprises Ltd. is a Nevada
corporation with its principal place of
business in Patchogue, New York.
Questions have arisen concerning the
accuracy and adequacy of publicly
disseminated information, including
information about the relationship
between the company’s business
prospects and the current Ebola crisis.
The company is quoted on OTC Link
(previously ‘‘Pink Sheets’’) operated by
OTC Markets Group Inc. (‘‘OTC Link’’),
under the stock symbol OGNG.
2. Immunotech Laboratories, Inc. is a
Nevada corporation with its principal
place of business in Monrovia,
California. Questions have arisen
concerning the accuracy and adequacy
of publicly disseminated information,
including information about the
relationship between the company’s
business prospects and the current
Ebola crisis. The company is quoted on
OTC Link under the stock symbol
IMMB.
3. Myriad Interactive Media, Inc. is a
Delaware corporation with its principal
place of business in Toronto, Canada.
Questions have arisen concerning the
accuracy and adequacy of publicly
disseminated information, including
information about the relationship
between the company’s business
prospects and the current Ebola crisis.
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Agencies
[Federal Register Volume 79, Number 227 (Tuesday, November 25, 2014)]
[Notices]
[Pages 70261-70263]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-27846]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-73649; 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 19, 2014.
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\ On November
23, 2010, the Commission extended the conditional temporary exemption
until December 2, 2011.\4\ On November 16, 2011, the Commission
extended the conditional temporary exemption until December 2, 2012.\5\
On November 26, 2012, the Commission extended the conditional temporary
exemption until December 2, 2013.\6\ On November 22, 2013, the
Commission extended the conditional temporary exemption until December
2, 2014.\7\ 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, 2015.
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\1\ See 17 CFR 240.17g-5(a)(3).
\2\ See 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\ See Exchange Act Release No. 63363 (Nov. 23, 2010), 75 FR
73137 (Nov. 29, 2010) (``First Extension Order'').
\5\ See Exchange Act Release No. 65765 (Nov. 16, 2011), 76 FR
72227 (Nov. 22, 2011) (``Second Extension Order'').
\6\ See Exchange Act Release No. 34-68286 (Nov. 26, 2012), 77 FR
71201 (Nov. 29, 2012) (``Third Extension Order'').
\7\ See Exchange Act Release No. 34-70919 (Nov. 22, 2013), 78 FR
70984 (Nov. 27, 2013) (``Fourth Extension Order'').
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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.\8\ Paragraph (a) of Rule 17g-5 \9\
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 \10\ and Rule 17g-1) \11\ 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).\12\ 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.
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\8\ 17 CFR 240.17g-5(b) and (c).
\9\ 17 CFR 240.17g-5(a).
\10\ 15 U.S.C. 78o-7(a)(1)(B)(vi).
\11\ 17 CFR 240.17g-1.
\12\ 15 U.S.C. 78o-7(h).
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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 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.\13\ 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) \14\ unless it has taken the
steps
[[Page 70262]]
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.\15\
Rule 17g-5(a)(3), among other things, requires that the NRSRO must:
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\13\ See 17 CFR 240.17g-5(a)(3); see also Exchange Act Release
No. 61050 (Nov. 23, 2009), 74 FR 63832 (Dec. 4, 2009) (``Adopting
Release'') at 63844-45.
\14\ 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).
\15\ 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; \16\ and
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\16\ Paragraph (e) of Rule 17g-5 requires that an NRSRO seeking
to access the hired NRSRO's Internet Web site 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 Sec. 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) of Rule 17g-5.\17\
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\17\ 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.\18\ 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.\19\ 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.\20\ 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.\21\ 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.\22\
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.\23\ 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.\24\
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\18\ Adopting Release at 63844.
\19\ Id.
\20\ Id.
\21\ Id.
\22\ Id.
\23\ Id.
\24\ 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.\25\ The Commission received six comment
letters in response to this solicitation of comment.\26\ The commenters
expressed concern that the extraterritorial application of Rule 17g-
5(a)(3) could, in the commenter's view, among other things, disrupt
local securitization markets,\27\ inhibit the ability of local firms to
raise capital,\28\ and conflict with local laws.\29\ Several commenters
also
[[Page 70263]]
requested that the conditional temporary exemption be extended or made
permanent.\30\ The First Extension Order again solicited public comment
on issues raised in connection with the extra-territorial application
of Rule 17g-5(a)(3).\31\ One commenter requested that the Order be made
permanent, citing many of the same reasons set forth in prior comment
letters.\32\ The Second Extension Order again solicited public comment
on issues raised in connection with the extra-territorial application
of Rule 17g-5(a)(3).\33\ Commenters supported the exemption regarding
the extra-territorial application of the Rule,\34\ with one of those
commenters again requesting that the Order be made permanent.\35\ The
Third Extension Order again solicited public comment on issues raised
in connection with the extra-territorial application of Rule 17g-
5(a)(3). No comments were received. The Fourth Extension Order again
solicited public comment on issues raised in connection with the extra-
territorial application of Rule 17g-5(a)(3). One comment was received
and the commenter supported the exemption regarding the extra-
territorial application of the Rule.\36\
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\25\ See Order at 28828.
\26\ Letter from Masamichi Kono, Vice Commissioner for
International Affairs, Financial Services Agency, Japan, dated Nov.
12, 2010 (``Japan FSA Letter''); Letter from Masaru Ono, Executive
Director, Securitization Forum of Japan, dated Nov. 12, 2010 (``SFJ
Letter''); Letter from Rick Watson, Managing Director, Association
for Financial Markets in Europe/European Securitisation Forum, dated
Nov. 11, 2010 (``AFME Letter''); Letter from Jack Rando, Director,
Capital Markets, Investment Industry Association of Canada, dated
Sep. 22, 2010 (``IIAC Letter''); Letter from Christopher Dalton,
Chief Executive Officer, Australian Securitisation Forum, dated Jun.
27, 2010 (``AuSF Letter''); Letter from Takefumi Emori, Managing
Director, Japan Credit Rating Agency, Ltd. (``JCR''), dated Jun. 25,
2010 (``JCR Letter'').
\27\ See Japan FSA Letter; SFJ Letter; AFME Letter; JCR Letter;
AuSF Letter.
\28\ See AFME Letter; JCR Letter; AuSF Letter.
\29\ 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).
\30\ See Japan FSA Letter; SFJ Letter; AFME Letter; JCR Letter.
\31\ See Letter from Tom Deutsch, Executive Director, American
Securitization Forum, and Chris Dalton, Chief Executive Officer,
Australian Securitization Forum, dated Aug. 9, 2011 (``ASF/AuSF
Letter 1''); Letter from Jack Rando, Director, Capital Markets,
Investment Industry Association of Canada, dated Nov. 2, 2011
(``IIAC Letter 2'').
\32\ See ASF/AuSF Letter 1.
\33\ Letter from Chris Barnard to the Commission, dated Nov. 23,
2011 (``Barnard Letter''); Letter from Tom Deutsch, Executive
Director, American Securitization Forum and Chris Dalton, Chief
Executive Officer, Australian Securitisation Forum, dated Aug. 28,
2012 (``ASF/AuSF Letter 2'').
\34\ See Barnard Letter; ASF/AuSF Letter 2.
\35\ See ASF/AuSF Letter 2.
\36\ See Letter from Chris Barnard to the Commission, dated Nov.
26, 2013.
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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, 2015 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
Use the Commission's Internet comment form (https://www.sec.gov/rules/exorders.shtml); or
Send an email 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 Brent J. Fields,
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 email 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 Web site (https://www.sec.gov/rules/exorders.shtml). Comments
are also available for Web site 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, 2015.
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, 2015 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.
Brent J. Fields,
Secretary.
[FR Doc. 2014-27846 Filed 11-24-14; 8:45 am]
BILLING CODE 8011-01-P