NRSRO Regulation

We have more than thirty years’ experience representing credit rating agencies known as nationally recognized statistical rating organizations (NRSROs). Over this time, we have actively participated in the evolution of this important new field of law. In this regard, we worked with industry members, policy makers and regulators to develop a comprehensive new regulatory regime dedicated to NRSROs. Our work in this area includes:

• Providing input into the development of legislation that became the Credit Rating Agency Reform Act of 2006 to ensure a smooth transition for NRSROs from the old regulatory regime to the new one
• Providing input to the development of the International Organization of Securities Commissioners Code of Conduct Fundamentals for Credit Rating Agencies (IOSCO Code) and to the revision thereof
• Assisting with public testimony for Congressional hearings and SEC roundtables regarding NRSRO issues, including issues related to the Dodd-Frank Act
• Submitting comments to the SEC regarding proposed new rules and rule changes
• Advising re compliance with the NRSRO provisions of the Exchange Act and related rules
• Assisting with initial NRSRO registration and ongoing SEC filings
• Assisting with SEC examinations