S&P Changes Prepay Criteria Standard & Poor’s has changed its criteria for rating transactions that include loans with prepayment penalties. In a statement released last week, the rating agency said it will seek more “comfort” that prepayment penalties are enforceable through the use of reps and warranties. The change comes amid a looming July 1 effective date for an Office of Thrift Supervision rule that would remove prepayment penalties from the list of loan terms