Recently the Staff of the Division of Trading and Markets (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) published a report to Congress outlining the findings from the study the Commission was required to conduct by Section 939F of the Dodd-Frank Act (the “Report”).

The Commission was directed to deliver a report not later than 24 months after the date of enactment of Dodd-Frank containing the findings of a study on, among other things, matters related to (1) assigning credit ratings for structured finance products and (2) any recommendations for regulatory or statutory changes that the Commission determines should be made to implement the findings of the study.

In creating the Report, the Staff gathered information, conducted meetings with proponents of various models and other stakeholders, and reviewed 32 comment letters – six from nationally recognized statistical rating organizations (“NRSROs”) and 26 from other interested parties, including investors, trade organizations, non-profit organizations, brokerage and financial services firms, academics and individuals.

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