Association of Danish Mortgage Banks & Danish Mortgage Banks Federation
We agree with the definition
We recognize the interim period of a regulatory void explained by the EBA in relation to amending the EBA GL before the ITS specifying the mapping of ECAIs CQS enters into force in 2014. However, to avoid any confusion in the meantime, we find it appropriate if the EBA before December 31st 2013 would clearly outline the timetable leading up to the ITS including when the ITS will come into force and the mechanistic references to external credit ratings would then be eliminated.
In our opinion, the replacement of paragraph 4 of Box 2 and paragraph 2 of Box 3 in the Money Market Funds Guideline eliminates any forced mechanistic reaction to a down grade of a money market instrument.