May 2019 Benchmark Fallbacks Consultations

Supplemental Consultation on Spread and Term Adjustments for Fallbacks in Derivatives Referencing USD LIBOR, CDOR and HIBOR and Certain Aspects of Fallbacks for Derivatives Referencing SOR

This consultation sought input on the approach for addressing certain issues associated with adjustments that will apply to alternative risk-free rates (RFRs) if the fallbacks take effect. These adjustments are necessary because of the differences between the interbank offered rates and the RFRs.

The consultation is available here.  A set of graphs provided by Bloomberg to illustrate certain of the options for adjustments under consideration in the consultation is available here.

The deadline for responses to the consultation was July 12, 2019.

Consultation on Pre-Cessation Issues for LIBOR and Certain Other Interbank Offered Rates (IBORs)

This consultation related to pre-cessation issues and seeks comments on how derivatives contracts should address a regulatory announcement that LIBOR or certain other IBORs categorized as critical benchmarks under the EU Benchmarks Regulation are no longer representative of an underlying market.

The consultation is available here.

The deadline for responses to the consultation was July 12, 2019.

A webinar explaining the two consultations and featuring remarks from David Bowman of the US Federal Reserve Board and Edwin Schooling Latter of the UK Financial Conduct Authority is available here.

A recording of a market call answering questions about the two consultations is available here.

Written answers to frequently asked questions are available here.

Response on Options and Discretions

On January 24, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Central Bank’s (ECB) consultation on its approach to options and discretions under EU law. In the response, the associations highlight the efforts of...

Letter to SEC on US Treasury Clearing

On January 24, ISDA, the Alternative Investment Management Association (AIMA), FIA, the FIA Principal Traders Group (FIA PTG), the Institute of International Bankers (IIB), the Managed Funds Association (MFA) and the Securities Industry and Financial Markets Association (SIFMA) and its...

Response on EMIR Active Account Consultation

On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on the active account requirement (AAR) introduced under the revised European Market Infrastructure Regulation (EMIR 3.0). In the response, ISDA highlighted significant concerns about the proposed...