Stinson Leonard Street Dodd Frank

MAKING SENSE OF DODD-FRANK

The Dodd-Frank Act has broad and deep implications that will touch every corner of financial services and multiple other industries. This site, developed and maintained by attorneys at Stinson Leonard Street, is dedicated to making sense of this complex legislation and helping businesses understand how it will affect them specifically. Our Bloggers »

Dodd-Frank

SEC Issues Staff Summary Report of Examinations of Nationally Recognized Statistical Rating Organizations

by   |   November 16, 2012

The SEC has issued its second annual staff report on the findings of examinations of credit rating agencies registered with the SEC as Nationally Recognized Statistical Rating Organizations, or NRSROs.

The 2012 report discusses the staff’s findings and recommendations in eight areas, including whether the NRSRO conducts business in accordance with its policies, procedures, and methodologies, how it manages conflicts of interest, and whether it maintains effective internal controls.  The staff identified findings and made recommendations to all NRSROs.  Findings identified at one or more NRSROs include the following:

  • The methodology applied to rating certain securities appears to have been changed, but the change was not publicly disclosed for several months;
  • Certain securities were not timely downgraded in accordance with policies and procedures related to rating watch status;
  • Methodologies were published and disclosed inconsistently and in a less-than-transparent manner; and
  • Directors were not actively exercising their required oversight duties.

Check dodd-frank.com frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.