Rule 17g-5

In December 2009, the SEC amended Rule 17g-5 to impose additional disclosure and conflict of interest requirements on nationally recognized statistical rating organizations and, by extension, additional disclosure requirements on “arrangers” (defined as issuers, sponsors or underwriters) of structured finance products.  The amended rule was prompted by concerns about “ratings shopping” and the potential conflict of interest that arises in an arranger-pay model.  The compliance date for the amended Rule 17g-5 was June 2, 2010.

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