On behalf of our members, ISDA appreciates the opportunity to respond to this consultation, with the 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 that the ultimatedecision is reached that any of these indices should be discontinued.
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