Client Alert

Implications of Regulatory Reform for the Credit Rating Agencies

April 26, 2010

Kevin L. Petrasic and Emily Hartman

As the Senate struggles to find effective compromises for pending regulatory reform legislation, a number of key issues are framing the final scorecard for what constitutes meaningful regulatory reform. Certain issues have emerged or have been reemphasized in recent days as catalysts propelling the reform debate, and others have remained relatively constant in the pending House (H.R. 4173) and Senate (S. 3217) bills. While the bills have numerous issues in common, there are subtle differences even in these commonalities that may or may not be meaningful in crafting final legislation. One area of significant accord is the general treatment of national credit rating agencies, or Nationally Recognized Statistical Rating Organizations (NRSROs).

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