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

Created date


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.