On August 31st, the SEC issued a Report of Investigations cautioning credit rating agencies about deceptive ratings conduct and the importance of sufficient internal controls over the policies, procedures, and methodologies the firms use to determine credit ratings. The report stems from an Enforcement Division inquiry into whether Moody's Investors Service, Inc. violated the registration provisions or the antifraud provisions of the federal securities laws. The report says that because of uncertainty regarding a jurisdictional nexus between the United States and the relevant ratings conduct, the SEC declined to pursue a fraud enforcement action. The report notes that the Dodd-Frank Act provides that federal district courts have jurisdiction over SEC enforcement actions alleging violations of the antifraud provisions of the securities laws when conduct includes significant steps, or a foreseeable substantial effect, within the United States. The report also notes that the Dodd-Frank Act amended the securities laws to require nationally recognized statistical rating organizations to "establish, maintain, enforce, and document an effective internal control structure governing the implementation of and adherence to policies, procedures, and methodologies for determining credit ratings." SEC Press Release.