On July 26, the SEC adopted rules to remove credit ratings as eligibility criteria for companies to use short form registration to register securities for public sale.  Instead, one of four tests must be satisfied for an issuer to qualify for short form registration: (i) the issuer has issued (as of a date within 60 days prior to filing of the registration statement) at least $1 billion in non-convertible securities other than common equity, issued in primary offerings for cash, registered under the Securities Act; (ii) the issuer has outstanding (as of a date within 60 days prior to filing of the registration statement) at least $750 billion of such securities; (iii) the issuer is a wholly-owned subsidiary of a well-known seasoned issuer; or (iv) the issuer is a majority-owned operating partnership of a real estate investment trust that qualifies as a well-known seasoned issuer.  The rules will be effective 30 days after publication in the Federal Register.  SEC Release.