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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.

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EACRA response to ESMA consultation on CRA supervisory fees

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 […]

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Position papers

EACRA comments on ESRB Chair letter on procyclical impact of downgrades

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Position papers

EACRA response to ECB Monetary Strategy Review

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Position papers

EACRA response to ESMA consultation on guidelines for internal controls for CRAs

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Position papers

EACRA response to European Commission’s consultation on the implementatiion of the final Basel III reforms in the EU

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Position papers

EACRA response to ESMA consultation on Disclosure requirements applicable to credit ratings

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Position papers

EACRA response to UK FCA consultation on regulatory fees proposals for 2019/2020