SFA Response to the NAIC on Amendments to the P&P Manual
article by Structured Finance Association
On July 26, the Structured Finance Association (SFA), on behalf of the members of the NAIC task force, submitted a letter to the Financial (E) Committee of the NAIC on amendments made to the Purposes and Procedures (P&P) Manual of the NAIC Investment Analysts Office. The amendments would authorize the procedures for the SVO’s discretion over NAIC ratings designations through the filing exemption process. The SFA commends the NAIC incorporating feedback from the industry in their revised Amendments. The SFA asks the NAIC to provide investors whose security ratings are under review with the option to invite third parties into the discretion process sooner. SFA believes this will afford third parties, especially rating agencies, the opportunity to provide additional detail behind their rating analysis, and the NAIC additional time to evaluate such information.