June 12, 2015 Alert: SFIG Launches NRSRO Due Diligence Industry Guide

SFIG is pleased to share its Industry Guide on the Nationally Recognized Statistical Rating Organizations (“NRSRO”) Due Diligence rules.

SFIG’s Industry Guide initiative seeks to contribute to market openness and transparency via a series of guides that reflect “general consensus” opinions of members interested in those particular regulatory rulemakings.

Over the last several months, the SFIG NRSRO Due Diligence Working Group, including, but not limited to, lawyers, accountants, trustees, issuers, and underwriters, have worked together to define a consistent approach to the due diligence sections of the Securities and Exchange Commission’s (“SEC”) August NRSRO rules. This group focused particularly on Third-Party Due Diligence for Asset-Backed Securities, including new rules 15Ga-2, Rule 17g-10, revised Form ABS-15G, and Form ABS Due Diligence-15E. These rules go into operation on June 15, 2015.

Created under the chairmanship of Amanda Baker and Jan Stewart, of Mayer Brown, the views set forth in the Industry Guide do not constitute legal advice but instead reflect industry views and consensus positions on the questions presented based on various resources and numerous group discussions. All of the views set forth in the Industry Guide are subject to change as market practices develop and/or if additional guidance from the SEC and its staff becomes available. While presented as a consensus, we would highlight that the guide does not purport to represent that all viewpoints have been universally adopted by every SFIG member.   

Please contact Sairah.Burki@sfindustry.org or Amanda.Bateman@sfindustry.org with any questions.

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