The International Organization of Securities Commissions (“IOSCO”) published the comment letters to the consultation paper on Principles for Financial Benchmarks that was issued on April 16, 2013. The report sought public comment on a set of high-level principles for benchmarks used in global financial markets. Because of the wide diversity of benchmarks, IOSCO also asked for public comment on a subset of more detailed principles for benchmarks having specific risks arising from their reliance on submissions and/or their ownership structure.
Lofchie Comment: One of the remarkable things about the comments is the geographic diversity of their sources. This indicates the significance of the U.S. regulators reaching an agreement with non-U.S. regulators as to the application of the U.S. derivatives rules to non-U.S. market participants. Financial regulation is a global concern.
See below to view public comments:
Argus
Australian Financial Markets Association
Baltic Exchange
Barclays
BlackRock
BVI Bundesverband Investment und Asset Management
CME Group
Euribor-European Banking Federation (“EBF”)
European Federation of Energy Traders (“EFET”)
European Structured Investment Products Association (“EUSIPA”)
Federation of European Securities Exchanges (“FESE”)
German Banking Industry Committee
Global Financial Markets Association (“GFMA”)
Hong Kong Monetary Authority
ICE Futures Europe
ICIS – Reed Elsevier plc
Index Industry Association
ING
International Capital Market Association (“ICMA”)
International Swaps and Derivatives Association, Inc.
Intesa Sanpaolo
Investment Company Institute and ICI Global
Investment Management Association (“IMA”)
Japanese Bankers Association (“JBA”)
LCH.Clearnet
London Metal Exchange
London Stock Exchange Group (“LSEG”)
Markit
McGraw-Hill Financial
MSCI and IPD
Nationwide Building Society and Lloyds Banking Group
NYSE Euronex
Platts
Rate Validation Services
Reserve Bank of Australia
Rosa M. Abrantes Metz
Russell Investments
Standard Chartered Bank
STOXX Ltd.
Thomson Reuters
Tokyo Stock Exchange, Inc.
Unicredit
Vanguard Asset Management, Ltd.