CRA III is the third instalment of the EU's legislative response to the role and performance of credit rating agencies prior to, and during, the financial crisis. It finally came into force in summer 2013, following a lengthy legislative process which saw material amendment to most of the substantive provisions. ESMA has since published clarification on the scope of CRA III and consulted on how some of the provisions will be implemented. ESMA published Q&As at the end of 2013 to address some of the practical questions which arise. In this article, first published on Lexis®PSL Financial Services on 16 January 2014, Harry Edwards, a senior associate in Herbert Smith Freehill's financial services regulatory and banking litigation teams, considers the Q&As and the key areas of uncertainty which remain.
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