Where a CRA distributes its credit ratings by subscription, would disclosure of credit ratings only to its subscribers constitute “disclosure to the public” within the meaning of Article 10(2a) and would subscribers be permitted to trade on the basis of these credit ratings?

Where a credit rating agency discloses credit ratings, rating outlooks and information relating thereto on its public website, does such disclosure suffice to consider them no longer inside information under Regulation (EU) No 596/2014?

Are credit ratings, rating outlooks and information relating thereto, pursuant to article 10(2a) of Regulation No 1060/2009, presumed to be inside information until disclosure to the public, or should a case-by-case assessment of the conditions in Article 7 of Regulation (EU) No 596/2014 be anyhow carried out?

a) What are the rotation periods for “lead analysts”?

b) What are the rotation periods for “rating analysts”?

c) What are the rotation periods for “persons approving credit ratings”?

d) Are there any exceptions to the requirement to rotate lead analysts?

e) Are there any exceptions to the requirements to rotate rating analysts and persons approving credit ratings?

f) How are the rotation periods calculated?

(a) When should a CRA notify a rated entity about the publication of a credit rating or rating outlook to which the rated entity is subject?

(b) How much time is required to elapse before a CRA can publish a credit rating or rating outlook after it has been notified to the rated entity?