On August 27, 2014, the SEC adopted a number of new rules and amendments designed to improve the quality of credit ratings and increase credit rating agency accountability in accordance with the Dodd-Frank Act.

The newly adopted rules impose new obligations on ABS issuers and underwriters — applicable to both registered public offerings and unregistered exempt offerings — requiring such issuers and underwriters to publicly file any third-party due diligence reports that they obtain and requiring third-party due diligence providers to provide written certifications to each NRSRO that produces a rating related to the due diligence services rendered.