AFME published comments on ESMA consultation on Article 4(3) of the Credit Rating Regulation
27 April 2011
AFME and its members are extremely concerned by the approach proposed in the ESMA Consultation Paper which is not required by the Regulation and which has the very real potential to prohibit the use of credit ratings for regulatory purposes from major non-EU jurisdictions, including the US.
This would result in multiple increases in regulatory capital requirements and significant market distortions. It is not clear to AFME that the potential impact of the proposals in the Consultation Paper are fully appreciated and they consider that the effects are likely to be of a magnitude significantly greater than expressed in the impact study.
Full position paper
© AFME
