The SEC rule amendments codifying an existing exemption available to credit rating agencies concerning conflict of interest disclosure obligations and the ratings of structured finance products were published in the Federal Register. The rule changes will go into effect on September 13, 2019.
As previously covered, the exemptions will be available only if (i) the issuer of the relevant security is not a U.S. person and (ii) the credit rating agency reasonably believes that all offers and sales of the instrument will occur outside the United States.
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