The letter to the SEC outlines how implementation of such scale change proposals would harm rather than promote the process of restoring greater confidence in structured securities ratings by labeling such securities as different.
The ASF submitted a comment letter to the SEC in response to various proposals to establish separate ratings scales for securitization and structured credit instruments. The letter notes that while ASF believes that a number of measures should be taken to improve credit ratings for structured securities and to enhance related disclosures, the ASF does not believe that the scale change proposals will meaningfully advance these goals.
The letter outlines how implementation of such scale change proposals would harm rather than promote the process of restoring greater confidence in structured securities ratings by labeling such securities as different, without explaining the differences, as well as posing conflicts within the existing regulatory structure and imposing administrative burdens and increased costs on market participants and regulators. The letter also notes that as an alternative to the scale change proposals, the ASF supports giving consideration to a wide range of proposals that could lead to the CRAs providing meaningful additional information about structured securities credit ratings. On May 22, the ASF also submitted this letter to congressional counsel and staff.
Letter
© ASF - American Securitization Forum
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