2016年-FSB全球金融稳定委员会_Second_Review_of_the_Implementation_of_IOSCOs_Principles_for_Financial_Benchmarks_by_Administrators_of_EURIBOR_LIBOR_and_TIBOR_58页_1mb

Summary of the Second Review of the Implementation of IOSCO’s Principles for Financial Benchmarks by Administrators of EURIBOR, LIBOR and TIBOR

Core Content

This report outlines the findings of the second review of the implementation of the IOSCO Principles for Financial Benchmarks by the administrators of EURIBOR, LIBOR, and TIBOR (collectively referred to as the IBORs). It follows the First Review conducted in 2014 and provides an update on the progress made since then. The review was conducted by an IOSCO Review Team composed of members from various regulatory bodies, including the UK FCA, ASIC Australia, BaFin Germany, CFTC USA, FSMA Belgium, FSB South Africa, and JFSA Japan.

The report focuses on the governance, transparency, accountability, and quality of benchmark design. It also addresses the evolution of the benchmarks towards a more transaction-based methodology, as recommended by the FSB OSSG in the IBOR+ initiative.

Main Findings

1. Progress on Governance, Transparency, and Accountability

• All three administrators have made significant progress in implementing the principles related to governance, transparency, and accountability.
• The majority of the recommendations from the First Review have been implemented or are under ongoing work.
• There are still gaps and inconsistencies in the implementation of the Principles on benchmark design, particularly Principles 6, 7, and 9.
• The administrators have developed and improved their policies and procedures in areas such as conflict of interest, stakeholder consultation, and internal oversight.
• Some areas require further action, such as ensuring conflict of interest policies apply to all relevant individuals and publishing sufficient information about the Oversight Committee or equivalent bodies.

2. Quality of Benchmark Design

• The Review Team acknowledges the ongoing efforts by the administrators to evolve the benchmarks to better reflect market transactions, as part of the IBOR+ initiative.
• The work is still in the planning and consultation phase, and the final implementation of the relevant principles will depend on the outcomes of this work.
• The process of benchmark evolution should be seen as a vehicle for implementing the Principles, but benchmark design must remain responsive to changes in the underlying market.
• The Review Team emphasizes that the administrators should continue to align their practices with the objectives of the Principles.

3. Active Markets and Data Sufficiency

• A common theme across the three benchmarks is the need for further work to ensure that the transactions used for input data are from active markets.
• Procedures must be in place to handle situations where the underlying markets are not active or representative.
• The transparency of benchmark determinations (Principle 9) remains unmet by all three administrators, as they have not yet published an explanation of how specific benchmark determinations are made.
• The administrators have plans in place to address this, and the implementation of Principle 9 is expected to occur in parallel with the evolution of the benchmarks.

4. Regulatory and Oversight Environment

• The administrators are in jurisdictions with a changing regulatory environment for benchmarks.
• EURIBOR is currently administered by the European Money Market Institute (EMMI), which is not a supervised entity under the European Regulation on financial benchmarks.
• EMMI is in the process of consulting on open issues related to the transaction-based design of EURIBOR and its transition considerations.

Key Recommendations

• The Review Team has made recommendations for each administrator to strengthen the implementation of the Principles.
• IOSCO expects administrators to take decisive steps to implement the recommendations as soon as possible.
• A follow-up review is not recommended, as the majority of the recommendations have been implemented or are under ongoing work.
• National authorities should monitor the progress of the administrators in implementing the recommendations.

Background and Context

• The IOSCO Principles for Financial Benchmarks were published in July 2013 and consist of 19 principles aimed at promoting reliability, integrity, and accountability in benchmark determinations.
• The FSB and G20 Leaders endorsed the Principles as the global standard for benchmarks.
• The First Review (July 2014) identified gaps in the implementation of the Principles, particularly in benchmark design, data sufficiency, and transparency.
• The IBOR+ initiative was introduced to anchor the benchmarks in transaction data, and the FSB has been monitoring the progress of this initiative.

EURIBOR+ Implementation

• The EURIBOR+ project is an ongoing initiative to evolve EURIBOR into a transaction-based benchmark.
• It has been divided into two stages: the first stage was completed and focused on methodology development using transactional data from over 50 banks.
• The second stage is ongoing, involving transition planning and specifying operational requirements.
• EMMI has published a consultative position paper (October 2015) outlining the draft methodology for EURIBOR+ and the planning for its implementation.
• The goal is to reduce reliance on expert judgment and ensure the benchmark remains representative of the underlying interest.

Conclusion

The Review Team highlights that while significant progress has been made, especially in governance and transparency, the implementation of the Principles related to benchmark quality is still in progress. The transition to a transaction-based methodology is a key focus and should continue to be aligned with the objectives of the Principles. The administrators are expected to maintain momentum and ensure that any changes result in benchmarks that are reliable, transparent, and representative of the underlying market.