On May 18th, the SEC proposed rules implementing provisions of the Dodd-Frank Act concerning credit ratings and Nationally Recognized Statistical Rating Organizations ("NRSROs"). The proposal would require NRSROs to report on internal controls; protect against conflicts of interest; establish professional standards for credit analysts; and disclose the methodology used to determine a credit rating. The proposal also requires disclosure concerning third-party due diligence reports for asset-backed securities. Comments should be submitted within 60 days after publication in the Federal Register, which is expected during the week of May 23. SEC Press Release. See also Schapiro Remarks; Aguilar Remarks. Commissioner Kathleen Casey, while voting in favor of proposing the rule, reiterated her concern that the SEC is not fulfilling its obligations to engage in a rigorous cost/benefit analysis of its proposals. Casey Remarks.