The Dodd-Frank Wall Street Reform and Consumer Protection Act calls for the elimination of references to credit ratings in US banking regulations. This study's key finding is that US banks' lending to foreign borrowers does not appear to have been closely and consistently correlated with changes in sovereign credit ratings in the recent past. The evidence is weakest over 2007-2012. Thus, it is doubtful that the elimination of references to credit ratings will have a significant impact on banks' lending behaviour toward foreign borrowers. This finding lends support to serious consideration of alternative proposals, including those put forward by US regulators that seek to increase the sensitivity of capital requirements to sovereign risk levels, and one advanced in this study which relies on a joint regulatory mechanism by the BIS and the IMF.