“Credit Ratings” Removed From Regulations

By Alistair M. Nevius, J.D.


The IRS issued final regulations that remove all references to and all requirements of reliance on “credit ratings” from Treasury regulations (T.D. 9637). The regulations provide substitute standards of creditworthiness. They finalize rules that were issued in temporary form in 2011 to meet requirements mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act, P.L. 111-203.

The regulations remove references to “credit ratings” and “credit agencies” and functionally similar terms from the regulations. Most of the changes to the regulations involve simple deletions and/or substitutions where the words “credit ratings” or “credit agencies” appear.


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