Rule 17g-5 Exemption for Non-U.S. Persons

On May 19, the SEC issued an exemptive order stating that an NRSRO is not required to comply with Rule 17g-5(a)(3) until December 2 with respect to credit ratings for structured finance transactions where:  (i) the issuer of the structured finance product is a non-U.S. person, and (ii) the NRSRO has a reasonable basis to conclude that the structured finance product will be offered and sold upon issuance, and that any arranger will effect transactions of the structured finance product after issuance outside of the U.S.  The SEC is also requesting comments on the application of Rule 17g-5(a)(3) to transactions outside of the U.S. SEC Exemptive Order.