SEC Gives Japan’s Credit Rater a Conditional Rules Exemption
Published Date: 11/4/2026
Notice
Summary
The SEC is giving Japan Credit Rating Agency, Ltd. a special pass from some strict board rules that usually apply to rating agencies. This means they don’t have to follow certain independence and compensation rules for their board members right now. This conditional exemption helps them keep things running smoothly while they adjust, with no immediate money changes announced.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
SEC allows JCR to use supervisory committee
On November 2, 2026, the SEC granted Japan Credit Rating Agency, Ltd. (JCR) a conditional exemption allowing JCR to satisfy the requirements of Exchange Act Section 15E(t)(2) and Section 15E(t)(3) through its supervisory committee instead of the NRSRO board of directors. The order continues relief that previously was temporary (the prior order ran through October 30, 2026) and contains conditions JCR must meet.
Exemption tied to specific governance conditions
The exemption is conditional on at least 12 specific requirements, including that: at least half of the supervisory committee (but no fewer than two members) be independent; at least one independent member be a user of ratings; independent members serve no more than five years; independent members' compensation not be linked to JCR's business performance; supervisory committee deliberations be recorded and reports provided to Commission staff; and JCR must notify staff promptly of legal or rule changes and address staff recommendations from annual exams.
Ongoing SEC examinations and enforcement authority
Commission staff will continue to examine JCR annually under Exchange Act Section 15E(p) to confirm satisfaction of the order's conditions; if conditions are not fulfilled to staff's satisfaction, staff may recommend Commission action and the Commission may modify, suspend, terminate, or otherwise restrict the order. JCR must promptly provide requested supervisory committee records and reports to staff.
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