On February 9, the SEC proposed rule amendments, in connection with Section 939A of the Dodd-Frank Act, to remove the use of investment-grade ratings as a condition of "short-form" eligibility for public offerings of non-convertible securities, such as debt securities. A new test would be tied to the amount of debt and other non-convertible securities the company has sold in the prior three years. Comments must be submitted by March 28. SEC Release. Proposed Rule.