In principle, we agree that the proposed changes to paragraph 4 of Box 2 and paragraph 2 of Box 3 of the ESMA Money Market Funds Guidelines would help to avoid mechanistic reliance on credit ratings where such mechanistic assessments in practice are not already excluded by other means of regulation and/or restrictions.

However, we request that policy makers pay due regard to well established and well functioning internal risk processes that MMFs use to carry out credit assessments. We urge that disproportionate requirements with respect to the design, methodology and documentation of such internal credit quality assessment be avoided.