FIA, GFMA and ISDA submitted a joint response to the ESMA Discussion Paper on EU Financial Benchmarks Regulation. The three trade associations support the overall objectives of the EU Financial Benchmarks Regulation and recommend the endorsement of IOSCO Principles. They advocate for a regulatory framework which provides protection to the consumer and investor but does not create a burden which discourages contributor participation and call for the the principle of proportionality to be applied to the size and significance of the benchmark. They believe that recognition should be given to other standards within existing EU legislation to maintain consistency and recommend that the assessment for determining a critical benchmarks be defined and robust and for clear guidelines on third-country benchmarks.
