Terry M. Deru (Order Vacating Nationally Recognized Statistical Rating Organization and Municipal Advisor Bars)

UNITED STATES OF AMERICA before the SECURITIES AND EXCHANGE COMMISSION SECURITIES ACT OF 1933 Release No. 10084 / June 1, 2016 SECURITIES EXCHANGE ACT OF 1934 Release No. 77964 / June 1, 2016 INVESTMENT ADVISERS ACT OF 1940 Release No. 4412 / June 1, 2016 INVESTMENT COMPANY ACT OF 1940 Release No. 32137 / June 1, 2016 Admin. Proc. File No. 3-14404 In the Matter of TERRY M. DERU ORDER VACATING NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION AND MUNICIPAL ADVISOR BARS Terry M. Deru seeks to vacate an administrative order, dated July 11, 2012 (the "Order"), to the extent that it bars him from association with any nationally recognized statistical rating organization ("NRSRO") or municipal advisor.1 The NRSRO and municipal advisor bars at issue were imposed based solely on conduct occurring prior to July 22, 2010, the effective date of the Dodd-Frank Wall Street Reform and Consumer Protection Act.2 Accordingly, in our discretion, we vacate the Order to the extent it prohibits Terry M. Deru from associating with any NRSRO or municipal advisor, but otherwise leave the Order unmodified. By the Commission. Brent J. Fields Secretary 1 See Terry M. Deru, Securities Act Release No. 9336, Exchange Act Release No. 67407, Advisers Act Release No. 3431, Investment Company Act Release No. 30136, 2012 WL 2836958 (July 11, 2012). 2 See Koch v. SEC, 793 F.3d 147, 158 (D.C. Cir. 2015).