Introduction
On behalf of our members, ISDA appreciates the opportunity to respond to this consultation, withthe goal of contributing to a robust and stable financial market. In this response, we have limited ourselves to commenting on those issues that are directly relevant to ISDA and OTC Derivatives Markets. There are, of course, many important issues discussed in the consultation document that go beyond that scope, and we defer, in relation to those issues, to other financial market respondents with greater expertise and/or a more relevant focus. Equally, we will not address considerations of possible alternatives or successors to relevant indices (e.g. Libor or Euribor), either generically or specifically, in the case of those that we are aware will already be discontinued or those where a decision is yet to be made for the discontinuation of any indices/rates.
Our responses to selected questions where ISDA does have a comment can be found in full in the accompanying Annex 1. Our submission addresses ISDA concerns around financial benchmarks (eg benchmarks in the interbank market, including LIBOR) unless our response explicitly states otherwise, for example where we comment on the treatment of oil price reporting agencies(PRAs).
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