Submission #23

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APFIPP - Portuguese Association of Investment Funds, Pension Funds and Asset Management

Do you agree with the definition of sole or mechanistic reliance on ratings pro vided in this document? NA

Do you agree with the proposed action as regard EBA and ESMA Guidelines and Recommendations? NA

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

APFIPP welcomes the proposal set out by EBA of amending the Money Market Funds Guidelines with respect to the assessment of the credit quality of money market instruments by managers of Money Market Funds.

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Name of organisation APFIPP - Portuguese Association of Investment Funds, Pension Funds and Asset Management