On 25 January 2023, the US Securities and Exchange Commission (SEC) proposed a far-reaching rule (Rule 192) to prohibit securitisation transactions involving or resulting in a material conflict of interest between certain securitisation participants and investors. The rule is required by s 27B of the Securities Act,2 as inserted by s 621 of the Dodd-Frank Act.3 In this In Practice article the authors consider the impact of Rule 192 on UK and EU CLO managers.