Financial Benchmark Regulation - Comment Letter - CFA Institute - February 11, 2013

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Financial Benchmarks, IOSCO
First Report Released Consultation Released Comment Deadline
January 11, 2013 April 16, 2013 May 16, 2013

IOSCO Consultation Document on Financial Benchmarks
February 11, 2013

From the comment letter:

  • "Greater transparency underscores market discipline and helps mitigate conflicts of interest. Actual transaction data should be used in the compilation of benchmarks (where relevant) to the fullest extent possible."
  • "Other important measures to ensure the integrity of benchmarks include robust internal controls, policies, and procedures surrounding the assimilation and contribution of data for the calculation of benchmarks; adequate management reporting and supervision over the provision of inputs; policies to manage and mitigate conflicts of interest; and appropriate regulatory oversight."
  • "We believe that benchmark administrators and submitters should adhere to a code of conduct to ensure accountability. Codes of conduct should be supplemented by additional regulatory oversight of

submitters or administrators or both, where relevant and as appropriate, along with strong enforcement powers."

  • "We believe that regulators should limit themselves to the regulation of index production (where appropriate as outlined above) and not step into invasive regulation of index choice or limit index use."



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