SEC Extends Ford Motor Credit “No Action” Letter

On November 23, the SEC extended indefinitely the Ford Motor Credit “no-action” letter allowing issuers of ABS to omit credit ratings from registration statements filed under Regulation AB. The “no-action” letter was originally issued on July 22 in response to the repeal of Rule 436(g) as a result of the Dodd-Frank Act, which subjects credit rating agencies to expert liability for ratings disclosure. SEC Updated No-Action Letter.