NRSRO and Regulation AB II Final Rules Published in Federal Register
On September 15th, the Nationally Recognized Statistical Rating Organizations (“NRSRO”) final rule that applies to providers of third-party due diligence services for asset-backed securities was published in the Federal Register. The NRSRO final rule will be effective on November 14, 2014, except the amendments to § 240.17g–3(a)(7) and (b)(2) and Form NRSRO, which are effective on January 1, 2015; and the amendments to § 240.17g-2(a)(9), (b)(13) through (15), § 240.17g–5(a)(3)(iii)(E), (c)(6) through (8), § 240.17g–7(a) and (b), and Form ABS–15G, which are effective June 15, 2015. The addition of §§ 240.15Ga–2, 240.17g–8, 240.17g–9, 240.17g–10, and Form ABS Due Diligence–15E are effective June 15, 2015.

On September 24th, the Regulation AB II final rule for asset-backed securities disclosure and registration was also published in the Federal Register. The Regulation AB II final rule will be effective on November 24, 2014, and the compliance date for asset-level disclosures will be November 23, 2016.

If you are interested in joining SFIG’s Regulation AB II Task Force, please contact Alyssa Acevedo. Our Credit Rating Reform Task Force will focus on the NRSRO final rule. If you are interested in this task force, please contact Amanda Bateman.
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