Regulation AB

SEC Publishes Technical Corrections to Regulation AB II

On February 4, the SEC released certain technical corrections to rules that were published in the Federal Register on September 24, 2014. The changes effect Regulation AB and other rules governing the offering process, disclosure, and reporting for asset-backed securities. The corrections are effective February 6, 2015Release.

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.

SEC Proposes Revisions to Reg AB

On April 7, the SEC unanimously approved the publication of proposals to significantly revise Regulation AB and related rules. The proposals relate to, among other things, the offering process, disclosure, and reporting for asset-backed securities.  Comments are requested within 90 days of publication of the proposals in the Federal Register.  Proposed Rule.  Client Alert.