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Position papers

EACRA Response to ESMA consultation on proposed revisions to a Delegated Regulation and Annex I of CRAR

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Position papers

EACRA Response to EBAs Consultation Paper on Draft ITS on public disclosures by institutions

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Position papers

EACRA Response to ESAs consultation on ITS specifying certain tasks of collection bodies and certain functionalities of the ESAP

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Position papers

EACRA Response to ESAs consultation on DORA RTS on subcontrating ICT services

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Position papers

EACRA Response to EC consultation on Draft Delegated Regulation on harmonizing and simplifying ESMA supervisory fees

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Position papers

EACRA position on FIDA

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Position papers

EACRA response to EC Targeted Consultation on ESG Ratings and ESG Factors in Credit Ratings

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.

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Position papers

EACRA Position on European Single Access Point (ESAP) for financial and non-financial information

On November 25th, 2021, the European Commission tabled the Capital Markets Union Package[1], which includes amongst others a legislative proposal aiming at establishing the European Single Access Point (“ESAP”) for financial and non-financial information[2]. We note that ESAP is expected to have a very extensive scope, as it should cover 21 EU Regulations and 16 […]

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Position papers

EACRA Response to EC’s SME Listing Act consultation

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 […]

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Position papers

EACRA response to ESMA Consultation on Guidelines on Disclosure Requirements for Initial Reviews and Preliminary Ratings

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.