Third, many investors, including institutional ones, with the capacity to undertake their own credit analysis, did not undertake sufficient in-house examination of the risks in the assets underlying structured investments. Fourth, the role of credit rating agencies (CRAs) in the recent market developments has attracted attention.
A fair minded regulator should acknowledge that was a concern identified by industry some time ago. All these considerations led the EBA to be very careful in design of the buffer in two respects.