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BVI

We generally agree with the revised draft.
We generally agree with the revised draft. However, our members continuously complain about excessive fees charged and not transparent licensing models offered by CRA group entities for the provision of ratings data including also licensing practices for the CQS. Most recently, one member reported a 300 percent S&P ratings data cost increase offer compared with today through a combination of price and data usage policy changes. Our members continue to closely observe the non-transparent price increases in the credit rating industry and the practice to enter into license agreements which are typically made with an entity related to the registered CRA.

Therefore, we encourage the ESAs to analyse further the CRA derived data licensing practises on the use of credit ratings in the determination of the CQS codes. We welcome ESMA’s recent report on ratings data and the fact that ESMA is actively working to improve the transparency of activities of CRA-related data providers. This activity should also incorporate inappropriate CQS licensing behaviour.
BVI