Viewed from a competitive economic standpoint, there is no need for regulation. Credit rating regulation is justified only for supervisory purposes due to the stability of the financial market. Although the rotation rule increases the independence of credit rating agencies, it also distorts competition, reduces the quality of ratings and thus has a negative impact on growth. The rule on double ratings for structured finance instruments jeopardizes the stability of the financial market.
By upgrading a rating to “investment-grade rating”, public guarantees (or credits) can lead to a situation in which investors subscribe project bonds and thus encourage the participation of private investors. The “Europe 2020 Project Bond Initiative” should therefore be strictly limited to projects within the scope of trans-European networks.
Though the centralisation of the supervision of credit rating agencies with ESMA is justifiable, it is not absolutely necessary. At the same time, it is questionable whether or not it is inn line with EU law. Therefore, the maintenance of federal supervisory structures for ESMA and for the supervision rating agencies is a better solution.
The Commission is going too far. The Regulation should apply only to credit rating agencies whose ratings are to be used in the calculation by financial service providers of necessary own funds. Ratings of credit rating agency from outside the EU should also be useable to this end, when these agencies are subject to regulatory standards which are similar to those in the EU.
The rules on investment policy, maturity and liquidity increase investor confidence. Cash buffers for money market funds with a constant asset value are not suitable for striking the right balance between investor confidence and financial market stability. The only alternative is a general ban on money market funds with a constant redemption value. Banning money market funds from soliciting external credit ratings from rating agencies obstructs the efficient allocation of capital.
verboten , bei einer Ratingagentur ein Rating des MMF in Auftrag zu geben oder zu finanzieren (Art. 23).
Ratingagentur ein Rating des MMF in Auftrag gegeben oder finanziert, muss darauf hingewiesen werden, wenn das Rating im Prospekt oder anderen Mitteilungen an Investoren erwähnt wird (Art. 23).