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The Structure of LIBOR Oversight, Submission and Consultation FSB Official Sector Financial Conduct Authority Steering Regulates IBA and LIBOR submitters Group ICE Benchmark Administration LIBOR Submitters Administrates and controls LIBOR


  1. The Structure of LIBOR Oversight, Submission and Consultation FSB Official Sector Financial Conduct Authority Steering Regulates IBA and LIBOR submitters Group ICE Benchmark Administration LIBOR Submitters Administrates and controls LIBOR Benchmark Manager (CF40s) Assumed responsibiity in Feb 2014 Benchmark Submitters Leased from BBA indefinitely for £1 Oversight Committee Trade Associations,Submitters, IBA Panel Bank Forum ICE/CME ( Fed , BOE, SNB joined as observers April 2014) Structured like a risk committee

  2. Oversight Committee Members OVERSIGHT COMMITTEE Joanna Perkins (Chair) IBA David Bowman Federal Reserve System David Clark WMBA Clare Dawson LMA Chris Salmon Bank of England David Goone ICE Futures John Grout The Association of Corporate Treasurers George Handjinicolaou ISDA John Harding ICE Richard Kennedy UBS Brad Hurrell Barclays Sébastien Kraenzlin Swiss National Bank Kevin Ludwick Bank of Tokyo Mitsubishi Guy Sears IMA Frederick Sturm CME Group Paul Watson HSBC

  3. Goals f for L r LIBOR • Widen LIBOR definition to directly include more unsecured transactions o Current question (“At what rate could you borrow funds, were you to do so by asking for and then accepting interbank offers in a reasonable market size just prior to 11am London time?”) does not reflect current funding patterns. Question could be amended or dropped and a clearer statement of what LIBOR is intended to measure (bank unsecured o funding cost) put in place We believe the IBA position paper is reflective of this general viewpoint. o • To the extent possible, codify submissions based directly on or using reasonable models translating observed transactions into LIBOR submissions o Individual banks have made some progress but progress is not uniform and somewhat slow o IBA has now received submitting bank’s transactions data for most of 2014, which may help the process. • For USD LIBOR, consider whether a fully-transaction based rate is feasible and advisable, dropping the USD LIBOR panel altogether o Federal Reserve is analyzing data collected from FR2420 as well as CP data provided by DTCC o Statistically, a rate can be produced, but its robustness, usefulness, and practicality are all open questions and it would involve using transactions over a potentially long time span in any given day’s calculation. • Even if all these goals are ultimately met, we would still have financial stability concerns with LIBOR

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