(a) Could a non-EU CRA have a stake higher than 5% in a CRA registered in the EU and vice versa?

(b) Could an EU registered CRA acquire another EU registered CRA?

(c) For the purposes of Article 6a of the CRA Regulation, the term “shareholder” includes beneficial
owners as defined in Article 3(6) of Directive 2005/60/EC (Money Laundering and Terrorist
Financing Directive). Are collective portfolio managers considered as shareholders for the
purpose of Article 6a of the Regulation?

(d) Should portfolio managers be considered as shareholders under the last paragraph of Article
6a(1) as subjects in a position to exercise significant influence on the business activities of
collective investment schemes?

(a) Does ESMA need to previously authorise a deviation from the announced calendar of sovereign ratings and outlooks?

(b) In which cases would a CRA be able to deviate from the announced calendar of sovereign ratings and outlooks?

(c) Where the reason for a deviation from the announced sovereign ratings and outlooks calendar
is that an issuer appealed the CRA’s decision, shall the CRA specify that an appeal is the cause
of the deviation?

(d) How should CRAs disclose the reasons for a deviation from the announced calendar of sovereign ratings and outlooks?

(e) Are CRAs obliged to publish a rating action or a related rating outlook on the date announced in
their announced calendar of sovereign ratings and outlooks? In case of non-publication on the
announced date, are CRAs obliged to provide an explanation of the reasons for non-publication?

(f) In case of a deviation from the announced calendar of sovereign ratings and outlooks, what rules are applied to the publication of sovereign ratings and related rating outlooks?

(a) When do sovereign ratings or related rating outlooks have to be published?

(b) How to find out which markets are considered as “regulated markets”?

When does the obligation to publish sovereign ratings and related rating outlooks on Fridays enter
into force?

Paragraph 558 of the Guidelines (p.289) clarifies that ‘TRs should update the TSR based on the latest information for a given derivative as derived from the field ‘Event date’. Use case 4 in the Guidelines (p. 291) further illustrates that in the case of late reporting of historic events, the relevant information should be updated in the TR’s database only until the Event date of the subsequent event to avoid overwriting the information from more recent reports.

In this context, how should counterparties report historic corrections on outstanding derivatives that were not yet upgraded after EMIR Refit go-live (and thus no Event Date was previously reported for those derivatives)? How should trade repositories consider the sequencing of submissions to determine the validity of historic corrections?