The Association of Corporate Treasurers (ACT)and the Association Française des Trésoriers d'Entreprises (?AFTE?) have submitted a joint response to the Committee of European Securities Regulators' (CESR) consultation paper over itstechnical advice to the European Commission on possible measures concerning credit rating agencies (?CRAs?) issued in November 2004.

CESR was asked by the Commission to look at a possible registration system for CRAs in connection with barriers to entry to the ratings industry and secondly to consider codes of conduct.  From this analysis it was asked to recommend any strategic policy measures to deal with the issues raised.

Principal comments

• The ACT and AFTE believe that CESR is right to acknowledge the importance of the Code Fundamentals recently published by the International Organisation of Securities Commissions. They do however believe that a limited number of amendments to the Code Fundamentals will eventually be necessary to fully address some of their concerns.

• We believe that the IOSCO code should be allowed to bed in for a couple of years before any additional provisions by way of registration requirements or regulations are introduced.

• If, in the event, any form of registration or compliance filing is considered necessary for a CRA, we believe that a single such registration or filing should meet all compliance obligations throughout the EU for any legal entity.