The Dodd-Frank Act's Section 939A prompts banking regulators to remove any "reference to, or requirements of reliance on, credit ratings" in their regulations and capital requirements. The uncertainty of how regulators will interpret those words has the ABS industry bubbling and proposals emerging.

Like most Dodd-Frank mandates, the outcome is uncertain because the law left much of the interpretation in the hands of regulators, and they have until July to publish new rules.

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