The Commission believes that an integrated network of smaller rating agencies would have a wider scope and deeper level of cooperation. The Commission has assessed, with contributions from representatives of smaller CRAs, a number of possible areas which could be covered. As a result, the following issues have been identified by this assessment as areas where an integrated network could potentially have an added value: the development of a common data platform for underlying information used for developing ratings, the design and use of common methodologies, and the sharing of expert knowledge and best practices on a wide range of topics such as internal controls.
One of the problems with an integrated network is that it could lead to increased anti-competitive
behavior contrary to the European Union's objectives to enhance diversity in the rating industry.
The creation of a cooperation network was assessed as an alternative to the integrated network. It would be a forum for smaller CRAs, which would enable the establishment of a structure for ular exchange and cooperation among smaller rating agencies.