The recommendations also include the following main points:

- there is overreliance on external credit ratings, mainly due to excessive references to ratings in regulation;
- a clear distinction should be drawn between structured finance instruments and corporate financial instruments (corporate bonds). While corporate bonds are well established securities and its ratings were not inflated before the crisis the same cannot be said for structured finance instruments;
- European companies oppose extending the right of access to business information to other credit rating agencies than that hired by the issuer;
- a bottom-up approach should be preferred to increase competition (e.g. by encouraging the combination of mid-sized credit rating agencies). Were a new European Credit Rating Agency be created, corporate issuers should neither be required to obtain ratings from such a credit rating agency, nor to contribute to its funding; and
- it makes sense to continue to use the “issuer-pays” model, especially in respect of corporate debt.

Full position paper