EFAMA welcomes the opportunity to respond to the European Commission’s Call for Evidence on the ‘Review of the scope and third-country regime of the Benchmark Regulation.’
Asset managers use financial indices and benchmarks when managing portfolios on behalf of their clients. Integrity and accuracy of benchmarks and indices are critical to the pricing of many financial instruments, and therefore play an important role in building confidence in the market and its reflection of the real economy.
EFAMA believes that a balanced and proportionate regulatory framework is needed to efficiently deal with benchmarking risks (such as manipulation and conflicts of interest), without unjustifiably hampering investment opportunities or increasing burden and costs for end-investors.
EFAMA welcomes the opportunity to respond to the European Commission’s Call for Evidence on the ‘Review of the scope and third-country regime of the Benchmark Regulation.’
Following the EFAMA's partial response to the European Commission's targeted consultation on the regime applicable to the use of benchmarks administered in a third country, we would like to make additional comments on the ongoing review of the regime.
- Asset managers represent an important group of benchmarks’ users. In this context, EURIBOR rate is used by investment funds across all kinds of asset classes and financial instruments, as well as a benchmark for measuring fund performance, driving fee calculations and determining asset allocation.
- The identification of fallback rates for the contract with reference to EURIBOR are essential for asset managers and a stable and permanent approach would make the fallback clauses more robust and ensure further transparency.
A key purpose of the financial system is to allocate capital and risk in a manner that supports sustainable economic development and growth, including through the provision of financing, investment and hedging products. Financial benchmarks/indices are fundamental to the functioning of financial markets and are widely used in both retail and wholesale markets. In particular, benchmarks are a valuable tool helping market participants to set prices, measure performances, or work out amounts payable under financial contracts or instruments.