Response to joint Consultation on mechanistic references to credit ratings in the ESAs’ guidelines and recommendations

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

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.

Name of organisation

Association of Danish Mortgage Banks & Danish Mortgage Banks Federation