Response to joint Consultation on mechanistic references to credit ratings in the ESAs’ guidelines and recommendations

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In particular, do you agree with the proposed revisions of the ESMA Money Mar ket Funds Guidelines? If not, please suggest an alternative.

No, we do not agree with the proposed revision of these guidelines and propose instead that the outcome of the Money Market Funds Regulation currently under negotiations is awaited. While the proposed guidelines are fairly similar to the European Commission’s proposal, negotiations of this legislative file may end with a modified or different approach. This in turn could mean that the new guidelines would be revised soon again, thereby creating unnecessary burdens to users of money market fund ratings.
Please note that EACRA Members are currently not active in the rating of Money Market Funds and our position in this context is of general nature.

Note to Readers: EACRA currently represents 8 ESMA registered Credit Rating Agencies and 4 agencies recognized or registered outside of the European Union. The profile of EACRA members are available at our website:

Name of organisation

European Association of Credit Rating Agencies (EACRA")"