Author: Thomas Missong
With reference to the above consultation, we are pleased to hereby submit the views of our association. Our response focuses solely on questions relative to Credit Ratings raised in your consultation.
We very much welcome the very detailed consultation on the ESG rating market and on ESG factors in credit ratings. Since a high number of questions are addressed to users of ratings and companies subject to ESG ratings, we hereby provide our general views on both sections of this consultations only.
Dear ESMA, With reference to the above consultation paper dated January 28th, 2022, we are pleased to hereby submit the views of our association. In addition, individual EACRA Members may, in accordance with the EACRA Rules of Procedure, submit separate responses to you. The consultation paper mentions several times that the developments in the private […]
On November 25th, 2021, the European Commission tabled the Capital Markets Union Package, which includes amongst others a legislative proposal aiming at establishing the European Single Access Point (“ESAP”) for financial and non-financial information. We note that ESAP is expected to have a very extensive scope, as it should cover 21 EU Regulations and 16 […]
Dear S&P Global Ratings, With reference to your above Request for Comment dated December 6th, 2021, we are pleased to hereby submit the views of our association for your kind consideration. Before providing our views, we would like to recall the important principle of “non-interference with content of ratings or methodologies” as clearly stated in […]
Dear European Commission, EACRA welcomes the above consultation paper as well as the very detailed set of questions in the targeted consultation. One of the main objectives of the capital markets union action plan “is to ensure that companies, and in particular small and medium-sized enterprises (SMEs), have unimpeded access to the most suitable […]
EACRA welcomes the European Commissions proposed Banking package implementing the Basel III reform in Europe. In our view, the ECs overall approach corresponds to a faithful implementation of the globally agreed banking standards taking into account European specificities and the target to contain capital increases on banks. We believe that the proposed timetable (with an […]
In this response letter, we are providing responses to all questions raised to CRAs. We hope that our views and comments will assist ESMA in developing a final guideline leading to a common and shared understanding between ESMA and all CRAs to the benefit of all stakeholders, including issuers and investors alike.
ESMA proposes a number of changes to the current Delegated Regulation on CRA Supervisory fees, the key elements being: 1) the introduction of a flat annual supervisory of EUR 20.000 for CRAs with aturnover between EUR 1 and 10 mln. 2) the calculation of fees based on total turnover. 3) the introduction of an endorsement […]