Title

SEC Proposal Would Replace Regulation M Exemption for Investment Grade Securities
Client Memorandum

Created date

5/18/2011

As part of its efforts to remove reliance on and references to credit ratings from its rules and forms as required by Section 939A of Dodd-Frank, the SEC has issued proposed rules that would, among other things, eliminate the current exemption in Rules 101 and 102 of Regulation M for investment grade securities and replace it with an exemption based on a non-equity security's trading characteristics.