On October 7th, the SEC proposed for comment amendments requiring the disclosure of information regarding credit ratings used by registrants, including closed-end management investment companies, in connection with a registered offering of securities to better inform investors about credit ratings and their limitations. The amendments would require additional disclosure about potential conflicts of interest that could affect the credit rating, and the disclosure of preliminary credit ratings in certain circumstances. The proposed amendments would be applicable to registration statements filed under the Securities Act of 1933, the Securities Exchange Act of 1934 and the Investment Company Act of 1940, and Forms 8-K and 20-F. In a companion concept release, the SEC requested comment on whether it should propose rescinding Rule 436(g) under the Securities Act, which would cause nationally recognized statistical rating organizations to be included in the liability scheme for experts set forth in Section 11, as is currently the case for credit rating agencies that are not NRSROs. Comments on both the proposed rule and the concept release should be submitted on or before December 14, 2009.