Kirkland Alert Kirkland & Ellis LLP

Much Ado About Nothing?

On September 29, 2010, the Securities and Exchange Commission (SEC) issued a final rule amending Regulation FD to remove the exemption covering disclosures to rating agencies effective October 4, 2010. (17 C.F.R. 243.100(b)(2)(iii)). The amendment was mandated by Section 939B of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.