Form NRSRO-UPD Filings

What Is SEC Form NRSRO-UPD?

SEC Form NRSRO-UPD is an update of registration filed under Section 15E(b)(1) of the Securities Exchange Act of 1934 and Rule 17g-1. It is used by an NRSRO to amend its existing Form NRSRO when information or documents previously provided to the SEC become materially inaccurate.

This form is typically filed when a registered credit rating agency needs to update information in its Form NRSRO, including amended items or exhibits reflecting changes in operations, policies, procedures, or other required disclosures. Once filed, it updates the NRSRO’s registration record with the SEC and becomes part of the agency’s current regulatory disclosure record.

Form NRSRO-UPD helps keep NRSRO registration information current by requiring prompt amendment when previously filed information becomes materially inaccurate. It is an event-driven filing rather than a fixed annual or periodic report.

Key elements typically found in SEC Form NRSRO-UPD include:

• Name of the NRSRO
• Identification of the filing as an update to registration
• Items and/or exhibits amended
• Updated information responsive to the amended items or exhibits
• Signature of the authorized representative
• Public filing on EDGAR in PDF format after registration

SEC Form NRSRO-UPD Filing Deadlines

SEC Form NRSRO-UPD does not have a fixed periodic deadline. Instead, it must be filed when previously submitted information in Form NRSRO becomes materially inaccurate and needs to be updated. These timing requirements are important to maintain accurate registration disclosures.

Key Things to Know About Form NRSRO-UPD Filing Rules

• Material Inaccuracy Standard: An NRSRO uses Form NRSRO-UPD when information or documents previously filed in its Form NRSRO become materially inaccurate and need to be corrected or updated.
• Event-Driven Filing: Form NRSRO-UPD is not filed on a fixed annual or quarterly cycle. It is filed as needed based on changes that require an update to the NRSRO’s registration disclosures.
• EDGAR Submission Required: After registration, updates of registration must be filed electronically on EDGAR as PDF documents in the format required by the EDGAR Filer Manual.
• Website Posting Obligations May Apply: Current Form NRSRO and Exhibits 1 through 9 generally must be made publicly and freely available on an easily accessible portion of the NRSRO’s corporate website within 10 business days after filing the update.
• Separate from Annual Certification: Form NRSRO-UPD is distinct from the annual certification filing. It is used to update registration information when required, while annual certification is filed separately under Section 15E(b)(2).

Our SEC Edgar Search provides tools to search and monitor Form NRSRO-UPD submission activity, including programmatic access through the SEC EDGAR API. For a step-by-step walkthrough, see how to download SEC filing data directly from EDGAR0