Asset managers represent an important group of benchmark users, either in the case of index funds and exchange traded funds (ETFs) - where benchmarks are used as a target for index tracking funds - or in the case of the evaluation of an active manager’s performance - where the fund performance is measured against a selected index or a set of indices.

As representative of the asset management industry, EFAMA supports the European Commission’s proposal to ensure continuation of existing contracts referencing critical benchmarks such as the LIBOR if and when their continuity is at risk. Asset managers as supervised entities are mandated under BMR to have in place robust written plans in the case a benchmark ceases to exist or materially changes, targeting at ensuring such continuity. At the same time in the case of a critical benchmark it is not only of higher relevance but also necessary to ensure legal certainty as regards the fallback arrangements that will ensure such continuity.