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.

We completely agree with the proposed revisions of the ESMA Money Market Funds Guidelines. In fact they contribute to reducing the excessive and often mechanistic reliance to credit rating provided by CRAs in the context of money market fund management and ensure that requirements in Art. 5b(1) of the CRA Regulation are fulfilled.

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