Key Issues raised by the consultation feedback and revisions to the final report

The final report has been informed by the public comment letters received as part of the consultation process on the draft Principles on Financial Benchmarks, the summary of which can be found in Annex B.

In general, there was a good level of support for the Principles with the majority of comments on the technical detail rather than the substantive policy approach.

Below are a number of common issues raised in the feedback, which IOSCO considers warranted further clarifications. These clarifications are designed to help address misconceptions about the intended scope and implementation of the Principles and describe in further detail some key issues concerning the usage of transactions.

This chapter also describes how IOSCO has responded to the consultation feedback, both in terms of revised Principles and suitable application of the Principles.

Scope

The scope of the proposed Principles was deliberately kept very broad in the April Consultation Report, excluding only publically produced Benchmarks. Given this large scope, the Principles propose a multi-tiered approach to capture the particular risks of certain types of Benchmarks.

This approach and coverage was broadly supported by the public comments, including that the Principles should apply to equity Benchmarks, a point on which a specific question was asked. Nevertheless some respondents argued that certain Principles were not relevant for indices based on transaction data obtained from Regulated Markets and Exchanges and queried the definition of Submission.