Consultation Paper on CRA3 Implementation

Consultation Paper on CRA3 Implementation

from 11 February 2014 to 11 April 2014


Responding to this paper

ESMA invites comments on all matters in this paper. Comments are most helpful if they:

contain a clear rationale;
include quantitative elements to support any concern; and
describe any alternatives ESMA should consider, including alternative drafts.

ESMA will consider all comments received by 11 April 2014.

All contributions should be submitted online at under the heading ‘Consultations’.
Publication of responses

All contributions received will be published following the close of the consultation period, unless you request otherwise. Please clearly and prominently indicate in your submission any part you do not wish to be publically disclosed. A standard confidentiality statement in an email message will not be treated as a request for non-disclosure. A confidential response may be requested from us in accordance with ESMA’s rules on access to documents. We may consult you if we receive such a request. Any decision we make is reviewable by ESMA’s Board of Appeal and the European Ombudsman.
Data protection

Information on data protection can be found at under the heading ‘Disclaimer’.
Who should read this paper

Users and producers of credit ratings and anybody who is involved in the issuance of structured finance instruments (issuers, originators and sponsors) or interested in the up-to-date individual rating data or in competition in the credit market should read this paper. This includes institutional and retail investors, investment firms, asset management firms, issuers of any kind of debt, central banks, supervisory bodies but also academics and any stakeholder engaged in SFI activities.


Document available for this Consultation
11/02/20142014/150Consultation Paper on CRA3 Implementation


Activity Institution Download
True Sale International GmbH
True Sale International GmbH, Frankfurt, Germany
Asset Management BlackRock
Asset Management BVI
Banking SIPUG Switzerland
Banking German Banking Industry Committee / Die Deutsche Kreditwirtschaft
Banking European Investment Bank Group
Banking European Association of Public Banks
Credit Rating Agencies Japan Credit Rating Agency, Ltd.
Credit Rating Agencies Moody's Investors Service
Credit Rating Agencies A.M. Best Europe - Rating Services Limited
Credit Rating Agencies DBRS
Issuers Dutch Securitisation Association
Issuers Deutsches Aktieninstitut
Legal and Accountancy Clifford Chance LLP
Legal and Accountancy Allen & Overy LLP
Legal and Accountancy Financial Markets Law Committee
Others Investment Management Association
Others EFAMA
Others Association for Financial Markets in Europe
Others Rating-Agentur Expert RA GmbH
Others EACRA - European Association of Credit Rating Agencies
Others EuroABS Limited