ISDA represents a broad global range of over 800 OTC derivatives market participants including corporations, pension funds, insurance institutions, asset managers and otherinvestment 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 consultation 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 LIBOR rates, as published.
As previously noted in our response to the Wheatley Review of LIBOR initial discussion paper (“Wheatley Response”), ISDA fully recognises the importance of “reforming” LIBOR in terms of its governance and transparency and welcomes the opportunity to comment on the specific aspect of reducing the number of currencies and maturities for which LIBOR covers.
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