On February 9th, the SEC published proposed amendments that would remove credit ratings as one of the conditions for companies seeking to use short-form registration when registering securities for public sale. The proposal is the first in a series that the SEC will promulgate in accordance with the Dodd-Frank Act's requirement that references to credit ratings contained within existing SEC rules be replaced with alternative criteria. The proposed amendments would remove the investment grade credit ratings condition included in SEC forms S-3 and F-3 for offerings of non-convertible securities, such as debt securities. Instead of ratings, the new test would be tied to the amount of debt and other non-convertible securities the particular company has sold in the past three years. Comments should be submitted on or before March 28, 2011. SEC Press Release. See also Schapiro Remarks; Casey Remarks; Aguilar Remarks; Paredes Remarks.