XBRL Implementation Guide for Nationally Recognized Statistical Rating Organizations¹

Introduction

The Securities and Exchange Commission ("Commission") recently adopted new rules relating to the disclosure requirements for ratings actions of nationally recognized statistical rating organizations ("NRSROs").

The Commission adopted a disclosure rule in February 2009 to require any NRSRO to make and retain an internal record of the ratings history of each current credit rating. From that record, an NRSRO that operates under the "issuer-pay" model is required to publicly disclose a random sample of 10% of the ratings issued, with certain caveats ("10% Disclosure Rule"). The 10% Disclosure Rule requires an NRSRO to make the data publicly available in XBRL format.

Additionally, the Commission adopted a disclosure rule to require all NRSROs to make publicly available all credit rating action history related to outstanding credit ratings that were issued as of June 2007 ("100% Disclosure Rule"). The 100% Disclosure Rule also requires an NRSRO to make the data publicly available in XBRL format.

What XBRL taxonomy should be used for the rating actions disclosures?

The directory of taxonomies supported for the XBRL programs can be found at http://sec.gov/info/edgar/edgartaxonomies.shtml.

The following taxonomy architecture document and technical instructions provide guidance when preparing XBRL files for these disclosure requirements to help ensure the taxonomy is being used consistently.

• Credit Ratings Taxonomy Architecture Document

• Credit Ratings Taxonomy Technical Guide

• Credit Ratings Taxonomy Publication Guide

Where can the rating actions disclosures in XBRL format be found?

The rating actions disclosures in XBRL are required to be posted to each NRSROs website in accordance with compliance timelines in the adopting release. The Commission staff intends to create a central directory of the credit ratings XBRL files which will be made available from this webpage.

Other Resources

The adopting release for the rules relating to the new disclosure requirements for ratings actions of NRSROs can be found on the Commission's website at http://sec.gov/rules/final/2009/34-59342.pdf and http://sec.gov/rules/final/2009/34-61050.pdf

Additional materials regarding NRSROs generally are available on the Commission's website at http://www.sec.gov/divisions/marketreg/
ratingagency.htm.

Contacting the Commission

The Division of Trading and Markets is happy to assist with questions regarding the new rules. The Office of Interpretation and Guidance answers questions submitted by email and telephone. You can submit a question by email to tradingandmarkets@sec.gov or you can contact the Office of Interpretation and Guidance at (202) 551-5777.

For technical questions related to the use of XBRL and the taxonomies, please contact the Office of Interactive Disclosure. You can submit a question by email to ask-oid@sec.gov or you can call at (202) 551-5494.

¹ This summary was prepared by the staff of the Commission to explain rules adopted by the Commission but it is not a substitute for the rules themselves. Only the rules themselves can provide complete, definitive information regarding its requirements.

http://www.sec.gov/spotlight/xbrl/nrsro-implementation-guide.shtml