ISDA represents a broad global range of over 800 OTC derivatives market participants including corporations, pension funds, insurance institutions, asset managers and other investment companies, energy and commodities firms, clearing houses, government and supranational entities, as well as global and regional banks, and is very pleased to have the opportunity to respond to the discussion paper. Since the inception of OTC derivatives in the 1980s, its members have referenced Libor rates as the floating rate in the majority of their interest rate transactions. ISDA views itself and its membership as being a user of the rate, as published.
We are keenly interested in the integrity of Libor, but ISDA does not have any direct responsibility for the governance, management, constitution or methodology of Libor. As such, we will not be answering in any detail the Review’s questions which pertain to matters such as these. Equally, we will not address considerations of possible alternatives or successors to Libor (either generically or specifically) in the case that the ultimate decision is reached that Libor should be discontinued. Our responses to selected questions where ISDA does have a comment can be found in full in the accompanying Appendix.
Click here to download the response from ISDA.