ANSWER TO IOSCO s CONSULTATION ON FINANCIAL BENCHMARKS FEBRUARY 2013
|
|
- Toby Moore
- 6 years ago
- Views:
Transcription
1 ANSWER TO IOSCO s CONSULTATION ON FINANCIAL BENCHMARKS FEBRUARY 2013 Amundi is a leading asset manager, ranking second in Europe and among the top ten in the world with assets under management above 710 billion euros at the end of September It is active in many different countries and serves a diversified clientele of retail, corporate and institutional investors through a large range of products and investment solutions. If Amundi is not a direct participant of the industry of indices it is a regular user of benchmarks produced by others. As any asset manager, Amundi relies on market indices and benchmarks in different circumstances and specifically when it invests in financial instruments referenced to standard indices or duplicates performances of a benchmark through an ETF (Exchange Traded Fund) More commonly when discussing with clients and potential clients and presenting its expertise, Amundi will make references and comparisons to indices. But this usage for reporting and marketing purposes is of a totally different nature and should be treated separately. Amundi thanks IOSCO s Task force for the quality of its work and for the opportunity it offers through the present consultation to express views on the possibility to regulate production and use of benchmarks. It shares the general objective to reduce the risk for manipulation of benchmarks and to promote higher standards in this field. Amundi will only answer to the questions on which it has a specific view and/or a direct experience as a representative of the buy-side. As a foreword Amundi wants to outline the following key messages: Amundi thinks that time is needed to let analysis and reflexion conducted by IOSCO (and others as the European Commission) lead to the mature and adequate regulation that is expected; Amundi is keen to participate to this consultation process in order to achieve a better regulation or conclude that self-regulation is more efficient; Amundi shares the opinion that transparency, responsibility, accountability are principles that should apply through all the steps of the benchmark-setting process and concern methodology, governance and supervision; in particular, the examples of interbank offered rates as Libor or Euribor evidence the need for a better organisation relying on principles that could easily be applied on a voluntary basis; Amundi is concerned with the economic consequences of new regulation introduced by ESMA s guidelines on ETF and other UCITS issues with respect to free access by investors to information on the methodology and the components of benchmarks. As subscribers to the services of the benchmark producer, asset managers have access within short delay to most of the required information. On the other hand, public at large can only get a restricted access (if any) free of charge. The case of investors in the funds that refer to benchmarks (like ETFs) has to be addressed as they should legitimately have - 1
2 a larger access than the public but cannot require the asset manager to be in breach of its license contract and communicate confidential information. A realistic compromise should be found or imposed by regulation on the level of necessary information accessible at a reasonable cost; The global responsibility of the administrator of the benchmark should be expressed as an overarching principle, irrespective of the fact that it delegates to third parties different functions (contribution, collection of data, calculation, publication ); The global architecture that Amundi envisions for the organisation of the industry of benchmarks includes high level principles expressed by IOSCO and applied by professional code endorsed by local authorities as recommendable but not mandatory practices and a general supervision by local or regional authorities. Amundi s responses to specific questions are given below, following the order of the consultation. Only those questions where Amundi has specific comments to add are addressed. Chapter 1 Scope 1. Do you agree with the scope of the report and intended audience? Are there other Benchmarks or stakeholders that have idiosyncrasies that should place them outside of the scope of the report? Please describe each Benchmark or stakeholder and the idiosyncrasies that you identify and the reasons why in your view the Benchmark or stakeholder should be placed outside of the scope of the report. The definition of benchmark as provided in Annex A differs from the definition expressed by European Commission in its consultation on benchmarks, last November. As benchmark industry is a worldwide business we advise different bodies to agree on a common definition. More precisely we agree with the European approach to concentrate on benchmarks that are used for financial transactions. The use of benchmarks by asset manager for reporting or marketing purposes is under the scope of distribution and clientele relationship regulations and should not be subject to any regulation of benchmarks which should concentrate on processing and publishing of benchmarks. Chapter 2 Benchmark design 2. Do you agree that the design of a Benchmark should clearly reflect the key characteristics of the underlying interest it seeks to measure? Quality and integrity of Methodologies 3. What measures should Administrators take to ensure the integrity of information used in Benchmarking-setting and that the data is bona fide? Please highlight any additional measures required where Benchmarks are survey based. Please also comment on each of the factors identified in the discussion on the vulnerability of data inputs such as voluntary submission, discretion exercised by Administrators. Are these measures adequately reflected in the discussion of roles and responsibilities of the Administrator discussed in section E? 4. What measures should Submitters implement to ensure the integrity of information provided to Administrators? Are these measures adequately reflected in the discussion of a code of conduct for Submitters discussed in section E? In particular, should Submitters submit all input data and not a - 2
3 selection of such data so as to maximise the representation of the underlying market? Please comment on any practical issues that compliance with such an approach may give rise to. Answer to questions 3 and 4: Amundi totally supports the organization of responsibilities as described under A.5. For an end user of benchmarks like an asset manager, it is of prime importance to know that the person it has contracted with has full responsibility for the establishment and circulation of a benchmark. Thus, delegation should not lead to lower responsibilities of the Administrator vis à vis the bench mark users. The number of third parties involved into the process should not impact this overarching principle. Contrary to the Task force s opinion (expressed in 4.3 last ), Amundi does not favor the idea that benchmark administrator should communicate with the relevant authorities on suspicions regarding the submissions they receive. Twice in their recent history, under the Terror period in 1792 and during nazi invasion in 1940s, French institutions and people have heavily suffered of denunciation and cannot conceive not to demand more than suspicion before reporting to authorities. With reference to section E.1, Amundi is concerned with the high level of details required to be made public. Even if it shares the view that transparency is mandatory with a great level of details (see below) it feels that there should be a difference between information posted for access by the public and documents made available to professionals and/or authorities. It expects all details to be available in the framework of a due diligence, eventually with a confidentiality provision. But it thinks that a lesser degree of transparency should be made directly accessible. Transparency of Benchmark methodologies 5. What level of granularity with regard to the transparency of Methodologies would enable users to assess the credibility, representativeness, relevance and suitability of a Benchmark on an on-going basis and its limitations with respect to their intended use? Relevant factors could include; criteria and procedures used to develop the Methodology, type of data used, how data is collected, relative weighting of data used, how and when judgement is used, contingency measures (e.g., methods when transaction data is unavailable etc), publication of information supporting each Benchmark determination, etc. Please provide examples where you consider there are currently significant gaps in the provision of this information. Transparency of contingency provisions for episodes of market disruption, illiquidity or other issues 6. What steps should an Administrator take to disclose to Market Participants and other stakeholders the contingency measures it intends to use in conditions of market disruption, illiquidity or other stresses? Transparency over changes to the Methodology 7. What steps should an Administrator take to notify Market Participants of material changes to a Benchmark Methodology (including to Benchmark components) and to take their feedback into account? 8. How often should the Administrator review the design and definition of the Benchmark to ensure that it remains representative? Answer to questions 5 to 8: Transparency of methodology is key to a proper assessment of the quality of a benchmark. It is not sufficient to rely on the good reputation of an administrator to trust its benchmarks as, for illustration purpose, it proved to be more than dangerous to rely - 3
4 on credit rating agencies to negotiate reloading of some complex blind securitization schemes The point is to make a distinction between a total transparency with a high degree of precision on the general procedures, including the cases of emergency and market disruption, on one hand and the day to day management of the benchmark on the other hand. When acting on the basis of the disclosed procedures, the administrator of a benchmark should be granted to use flexibilities provided for without advance notice or prior consultation. Ex post information might be sufficient. However, advance notice is a requirement for the changes in components list or weighting as well as for any item necessary for a replication of the benchmark. Consultation of stakeholders might be appropriately organized within the Oversight Committee that is discussed later. We suggest that representatives of the buy-side participate to the Committee. Governance 9. The Consultation Report discusses a number of potential conflicts of interest that may arise at the level of the Submitters, between Submitters at different entities, and between Submitters, Administrators and other third parties. Are there other types of conflicts of interest that have not been mentioned that you consider may arise? If so, how best should these conflicts of interest be addressed? Are the measures discussed in the Consultation Report sufficient to address potential conflicts of interests at the level of the Submitters, between Submitters at different entities, and between Submitters, Administrators and other third parties? 10. Do you agree that the Administrator should establish an oversight committee or other body to provide independent scrutiny of all relevant activities and management of conflicts of interest? Please comment if and why any different approaches might be appropriate for different kinds of Benchmarks. What is the minimum level of independent representation this committee or body should include? Answer to questions 9 and 10: Amundi totally supports the idea of establishing an Oversight Committee to enhance transparency and credibility of the concerned benchmark. It feels that this will be a major step to a better governance and should be quite efficient in appropriately addressing conflicts of interests and other issues relating to benchmark administration. Amundi considers that representatives of the buy-side should be invited to join such committees as their advice as users should be considered. It acknowledges, however, that participation to the Committee may result in a new type of conflict of interests that could be taken care of by an appropriate code of good conduct applying to the members of the Committee. This code should at least insist on confidentiality and absence of use of the participation as a marketing tool. The buy-side could also be represented to the Committee by professional associations. Accountability 11. Should the Submitters establish accountability procedures to assess their compliance with operational standards and scrutiny of Benchmark submissions? 12. Are the measures discussed in the Consultation Report (e.g. Audit Trail, external audits and requirement for regulatory cooperation) sufficient to ensure the accountability of Submitters? Should additional mechanisms be considered? 13. How frequently should Submitters be subject to audits? Should these be internal or external audits? - 4
5 Accountability of the Administrator 14. Are the measures discussed in the Consultation Report (e.g., complaints process, Audit Trail, external audits and requirement for regulatory cooperation) sufficient to ensure accountability of the Administrator? Should additional mechanisms be considered? 15. If recommended, how frequently should Administrators be subject to audits? Should these be internal or external audits? 16. Is public self-certification of compliance with industry standards or an industry code another useful measure to support accountability? This approach might also contemplate explanation of why compliance may not have occurred. If so, what self-certification requirements would make this approach most reliable and useful to support market integrity. Answer to question 16: Self-certification of compliance with industry code presents in Amundi s view the advantage of enabling a standard approach and a common level of quality worldwide. It gives users a framework for analyzing and scrutinizing on common principles the quality of benchmarks and benchmark administrators. In that respect it is more effective than a regulatory approach that might differ from one country or one region to another. This applies not only with a view to the relationship of the administrator with submitters (which should be contractually defined with enforceable value) but more generally to all the process of benchmark setting and publishing. Code of conduct for Submitters 17. The Consultation Report discusses elements of a code of conduct for Submitters. Are the measures discussed (e.g., adequate policies to verify submissions, record management policies that allow the Submitter to evidence how a particular submission was given, etc.) sufficient to address potential conflicts of interest identified or do you believe that other control framework principles should be added? Answer to question 17: Amundi supports the idea of a code of conduct for submitters, but thinks that the code will only state general principles and will not be sufficient to address all issues. Thus, it stresses that a contract should be signed between the administrator and each submitter that will include more detailed and better adapted provisions. 18. What would be the key differences in the code of conduct for Benchmarks based on different input types, for example transactions, committed quotes and/or expert judgement? Chapter 3 Approaches to enhanced oversight 19. What are the advantages and disadvantages of making Benchmark submissions a regulated activity? 20. What are the advantages and disadvantages of making Benchmark Administration a regulated activity? Answer to questions 19 and 20: On one hand, many submitters and administrators are already part of regulated institutions. It may create a discrepancy and develop an uneven playing field or an incentive to circumvent legislation not to subject the benchmark industry to direct regulation and oversight. In any case, it would not be sensible to regulate submitters only and not administrators. The proper way to proceed consists in regulating administrators and have them control submitters. That leads to the following suggestion: direct regulation of administrators and indirect regulation of submitters. - 5
6 On the other hand, to have a central data base of all benchmark and indices providers, however appealing, does not sound realistic. And requiring them to register is not appropriate as some official bodies, for example INSEE in France, produce with high professionalism indices that might no longer be used by lack of registration. Regulation may be counter-productive and divert participants to use freely accessible robust benchmarks. Clients best interest is definitely not to increase costs through excessive regulation. Amundi considers that the objective is to reach harmonized framework worldwide and suggests that a declination through professional code of conduct of international principles established by IOSCO could be a correct approach. Further down in granularity, contracts signed with the Administrator should deal with specific details. Freedom to continue relationship with nonparticipating administrators should be left open, on a case by case basis. Thus a non-exclusive regulatory framework should be considered as a safe harbor for a proper issuance and use of benchmarks. Participating administrators could be submitted to effective control of compliance with the code by local or regional authorities (provided they endorsed it). 21. Do you agree with the factors identified for drawing regulatory distinctions? What other factors should be considered in determining the appropriate degree of oversight of Benchmark activities (discussed in Chapter 3)? Please provide specific recommendations as to how the distinctions discussed in Chapter 3 should inform oversight mechanisms. 22. What distinctions, if any, should be made with regard to Benchmarks created by third parties and those created by regulated exchanges? Answer to questions 21 and 22: Amundi agrees with the suggestion that distinctions should be introduced among benchmarks. As an example, it draws IOSCO s attention to the fact that benchmarks used as underlyings for futures and options listed on regulated markets should be considered as standard products and should not require any due diligence on the part of the investor. Asset managers should be able to rely on the examination of the regulated exchange to consider the benchmark as adequate. As a further example, Amundi believes that benchmarks used in a transaction with retail investors should be more closely supervised than benchmarks specifically asked for by an institutional investor. 23. Assuming that some form of enhanced regulatory oversight will be applied to an asset class Benchmark, should such enhanced oversight be applied to the Submitters of data as well as the Administrator? 24. What are the considerations that should be taken into account if the Submitters to a Benchmark operate in an otherwise unregulated market (e.g., physical oil, gold or agricultural commodity markets) and are not otherwise under any obligation to submit data to an Administrator? 25. Do you believe that a code of conduct, either on its own or in conjunction with other measures outlined within the report, would provide sufficient oversight to mitigate the risks that have been identified in Chapter 2? What measures should be established in conjunction with a code of conduct? For which Benchmarks is this approach suitable? 26. What other measures outlined in the report, if any, should apply in addition to a code of conduct? If you believe a code of conduct, either on its own or in conjunction with other measures outlined within the report, would provide sufficient oversight to mitigate the risks that have been identified in Chapter 2, what type of code of conduct should apply (e.g., a voluntary code of conduct, an industry - 6
7 code of conduct submitted to and approved by the relevant Regulatory Authority, a code of conduct developed by IOSCO, etc.)? 27. Do you believe that the creation of a Self-Regulatory Organisation (.e.g., one that exercises delegated governmental powers) and itself subject to governmental oversight, whether or not in conjunction with industry codes is a viable alternative for sufficient oversight and enforcement to mitigate the risks that have been identified in Chapter 2? For which Benchmarks is this approach suitable? What if any complementary arrangements might be necessary, such as new statutory obligations or offences for Administrators and/or Submitters? 28. Do you believe that, for some Benchmarks, reliance upon the power of securities and derivatives regulators to evaluate products that reference a Benchmark or exercise their market abuse or false reporting powers creates sufficient incentives for the Administrator to ensure sure that Submitters comply with a code of conduct? Answer to question 28: Amundi believes that powers of enforcement of authorities and jurisdictions in case of market abuse or false reporting are very efficient to impose compliance to good practice principles. In the case of Euribor and Libor alleged manipulations, prosecution has certainly enhanced improvement of former habits. It shows that the area is not exempt of regulations and that abuses and fraud can be properly dealt with. There is then no urgency to act and time is necessary to achieve the best balance between risk, cost and innovation. 29. Do you believe that users of a Benchmark, specifically, the users who are regulated or under the supervision of a national competent authority should have a role in enhancing the quality of Benchmarks? Which form should this role take: on a voluntary basis (e.g. the user being issued a statement that will only use Benchmarks that follow IOSCO principles), or on a compulsory basis (e.g., the competent authority could request that users who are registered under their jurisdiction should only use Benchmarks that fulfil IOSCO principles)? Answer to question 29: regulated users such as asset managers do participate to the enhancement of the quality of benchmarks through the due diligence inquiries they conduct when using a benchmark. Furthermore in Europe ESMA published specific requirements in that respect when issuing Guidelines on ETFs and other UCITS issues. Amundi feels that benchmarks used as underlying for listed future and option contracts should be validated at the level of the regulated exchange or MTF that lists them. A voluntary approach is recommended for the asset management industry as there are many types of clients and different situations that cannot be encompassed by a mandatory approach. For example if Amundi supports the new European regulation on UCITS that are aimed at retail investors, it considers that some flexibility is necessary when dealing with institutional clients that may have very specific requirements in terms of benchmarks. Furthermore, Amundi stresses the fact that the use of benchmarks for reporting and marketing purposes should not be considered as an activity to be regulated otherwise than through clientele relationship and distribution regulations. European directives and regulations are quite explicit in that respect. Finally, the question of cost resulting from regulatory requirements appears to be quite significant when discussing with benchmark administrators. They seem very keen to charge extra fees for circulation to the holders of a fund of information relative to the composition, the methodology or the governance of a benchmark. A reasonable cost approach should be part of the principles applying to benchmark administrators, and transparency should also apply to their pricing policy. - 7
8 Chapter 4 Data sufficiency 30. Do you agree that a Benchmark should be anchored by observable transactions entered into at arm s length between buyers and sellers in order for it to function as a credible indicator of prices, rates or index values? How should Benchmarks that are otherwise anchored by bona-fide transactions deal with periods of illiquidity due to market stress or long-term disruption? 31. Are there specific Benchmarks for which you consider that observable transactional data is not an appropriate criterion or the sole criterion? If so, please provide a description of such Benchmarks and what value you think such Benchmarks provide? 32. What do you consider the limitations or value in Benchmarks referencing asset classes and underlying interests where there is limited liquidity? Please describe the uses and value of such Benchmarks in the financial markets. 33. Do you agree that the greatest weight should be given to transactions in the construction of a Benchmark and that non-transactional information should be used as an adjunct (e.r., as a supplement) to transactions? Answer to question 30 to 34: reference to effective transaction prices should be preferred when available but cannot be considered as the only valid source of data. There are many instances where other data are more appropriate: bond prices are better reflected on bid/ask quotations continuously updated than on transactions prices; emerging market securities are another example where quotes are more significant than price. It is true that on highly liquid markets with many participants there is no justified alternative to transaction price, but it does not mean that benchmarks should be limited to that kind of markets. Benchmarks are efficient ways for investors to judge of the diversification of their investments and to properly adapt them. Innovation in the field of benchmarks may lead to an alternative kind of investment, be it through an ETF or through direct investment, for the benefit of the investor. More than liquidity the accuracy of the price discovery system as mentioned p 40 is the key reference : it will enable benchmarks to develop on less liquid markets. However these benchmarks should be submitted to specific care as they may be more easily subject to manipulation or conflicting interests. 34. What factors and how often should Administrators (or others) consider in determining whether the market for a current Benchmark s underlying interest is no longer sufficiently robust? What effective methods of review could aid in determining the insufficiency of trading activity within the market for a Benchmark s underlying interest? Transition 35. What precautions by Benchmark Administrators, Submitters, and users can aid Benchmark resiliency during periods of market stress, mitigating the potential need for market transition? 36. What elements of a Benchmark living will, drafted by a Benchmark Administrator, should be prioritised? 37. By what process, and in consultation with what bodies, should alternatives be determined for Benchmark replacement? - 8
9 38. What characteristics should be considered when determining an appropriate alternate Benchmark? (Examples below) Should any of these factors be prioritised? o Level and Type of Market Activity o Diversity/Number of Benchmark Submitters o Length of historical price series for the Benchmark alternative o Benchmark Methodology o Existing regulatory oversight o Existing enforcement authority o Volume, tenors and contract structure of the legacy trades 39. What conditions are necessary to ensure a smooth transition between market Benchmarks? 40. What considerations should be made for legacy contracts which reference a Benchmark in transition? To what extent does a substantive legacy book preclude transition away from a Benchmark? What provisions can be included in [new and existing] contract specifications which would mitigate concerns if and when a Benchmark transitions occurs? 41. How should a timeframe be determined for market movement between a Benchmark and its replacement? What considerations should be made for: o Altered regulatory oversight? o Infrastructure development/modification? o Revisions to currently established contracts referencing the previous Benchmark? o Revisions to the Benchmark Administrator? o Risk to contract frustration Answer to questions 34 to 41: Amundi shares the view that benchmarks and indices are brought to light one day and may die another day. It is as important to organize for innovative creation of new benchmarks as to make sure they are still representative. Stress resilience and market representation of the index or benchmark are essential characteristics and this last section of the consultation is not the least interesting. For an asset manager it is on one hand very difficult, except for benchmarks used for reporting purpose as reference to compare performances or define an investment universe, to ask investors to change reference. It can effectively occur mainly when the previous benchmark is no longer published. On the other hand, the asset manager can easily measure benchmarks that are representative of market segments or investment strategies of interest to investors at a given time: new subscriptions are directed to funds that refer to them. And it may change. Thus asset managers assess more often the interest of a fund within a product range than the interest of a benchmark. But at the end of the day it comes down to the same conclusion: products (funds or benchmarks) have to be monitored and their adequacy regularly reassessed. Usually commercial and legal considerations help to make that choice, but defective production of the benchmark is a case that cannot be argued against. Regulation should again limit itself to general principles in this field. - 9
10 Contact at AMUNDI : Frédéric BOMPAIRE Public Affairs 90, boulevard Pasteur PARIS 33 (0) frederic.bompaire@amundi.com Siège social : 90, boulevard Pasteur Paris - France Adresse postale : 90, boulevard Pasteur Paris Cedex 15 France Tel. : +33 (0) Fax: +33 (0) amundi.com Société Anonyme au capital de euros RCS Paris Société de Gestion de Portefeuille agréée par l'amf (Autorité des Marchés Financiers) sous le n GP
Ms Bopelokgale Soko Assistant Vice President Regulation and Compliance Bourse Africa Limited
RESPONSE TO THE IOSCO S CONSULTATIVE REPORT ON FINANCIAL BENCHMARKS Ms Bopelokgale Soko Assistant Vice President Regulation and Compliance Bourse Africa Limited All views in this submission are a personal
More informationIOSCO Public Consultation on Financial Benchmarks
February 2013 IOSCO Public Consultation on Financial Benchmarks Reply from NASDAQ OMX The NASDAQ OMX Group, Inc. delivers trading, exchange technology, listings and other public company services and post-trading
More informationIOSCO CONSULTATION FINANCIAL BENCHMARKS PUBLIC COMMENT ON FINANCIAL BENCHMARKS
IOSCO CONSULTATION FINANCIAL BENCHMARKS PUBLIC COMMENT ON FINANCIAL BENCHMARKS General Comments: Standard Chartered Bank welcomes the opportunity to participate in and provide comments to this consultation.
More informationResponse to questions on the IOSCO consultation report on Financial Benchmarks. Via electronic submission
55 Water Street New York, NY 10041 United States 11 February 2013 One Snowden Street London, EC2A 2DQ United Kingdom Mr. Alp Eroglu International Organization of Securities Commissions (IOSCO) Calle Oquendo
More informationICAEW is pleased to respond to your request for comments on CR 01/13 Financial Benchmarks.
Our ref: ICAEW Rep 26/13 Your ref: CR 01/13 Mr Alp Eroglu International Organisation of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain Via email: benchmarksconsultationresponses@iosco.org
More informationING feedback on the IOSCO consultation document on financial benchmarks
ING feedback on the IOSCO consultation document on financial benchmarks 8 February 2013 About ING ING is a global financial institution of Dutch origin, offering banking, investments, a variety of life
More informationChief Executive Officer S&P Dow Jones Indices
Alexander J. Matturri, Jr. Chief Executive Officer S&P Dow Jones Indices 55 Water Street New York, NY 10041 212-438-5530 Tel 212-438-5582 Fax alexander_matturri@spdji.com February 11, 2013 Mr Alp Eroglu
More informationESMA-EBA Principles for Benchmark-Setting Processes in the EU
ESMA-EBA Principles for Benchmark-Setting Processes in the EU 6 June 2013 2013/659 Date: 6 June 2013 ESMA/2013/659 Table of Contents List of acronyms 3 Principles for Benchmark-Setting Processes in the
More informationBenchmarks regulation, BMR An asset manager s view on ESMA s advice
Benchmarks regulation, BMR An asset manager s view on ESMA s advice A presentation by Frédéric BOMPAIRE Round table on January 31st, 2017 Hosted in Brussels by QED The following slides come as an illustration
More informationMSCI RESPONSE TO THE IOSCO FINANCIAL BENCHMARKS CONSULTATION REPORT
MSCI RESPONSE TO THE IOSCO FINANCIAL BENCHMARKS CONSULTATION REPORT February 11, 2013 MSCI Inc. is a leading provider of investment decision support tools to institutional investors globally, including
More informationFRENCH BANKING FEDERATION RESPONSE TO THE ESMA AND EBA CONSULTATION DOCUMENT REGARDING THE PRINCIPLES FOR BENCHMARKS-SETTING PROCESSES IN THE EU
FRENCH BANKING FEDERATION RESPONSE TO THE ESMA AND EBA CONSULTATION DOCUMENT REGARDING THE PRINCIPLES FOR BENCHMARKS-SETTING PROCESSES IN THE EU The Fédération Bancaire Française (the French Banking Federation,
More informationConsultation Paper. Principles for Benchmarks-Setting Processes in the EU. 11 January 2013 ESMA/2013/12
Consultation Paper Principles for Benchmarks-Setting Processes in the EU 11 January 2013 ESMA/2013/12 Date: 11 January 2013 ESMA/2013/12 Responding to this paper ESMA and EBA invite comments on all matters
More informationPRESS RELEASE. ESMA and the EBA publish final principles on benchmarks
Date: 06 June 2013 ESMA/2013/684 PRESS RELEASE ESMA and the EBA publish final principles on benchmarks The European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) have
More informationStatement regarding IOSCO Principles
Statement regarding IOSCO Principles Introduction The "Principles for Financial Benchmarks" ("Principles") were published by the International Organization of Securities Commissions ( IOSCO ) on 17 July
More informationI O S C O A N D E U B E N C H M A R K S R E G U L A T I O N S U P P L E M E N T A L D I S C L O S U R E
I O S C O A N D E U B E N C H M A R K S R E G U L A T I O N S U P P L E M E N T A L D I S C L O S U R E J. P. M O R G A N S E C U R I T I E S P L C J. P. M O R G A N S E C U R I T I E S L L C IOSCO and
More informationEFAMA REPLY TO THE EBA / ESMA CONSULTATION PAPER FOR BENCHMARKS SETTING PROCESSES IN THE EU
EFAMA REPLY TO THE EBA / ESMA CONSULTATION PAPER FOR BENCHMARKS SETTING PROCESSES IN THE EU EFAMA 1 welcomes the opportunity to provide comments on the EBA / ESMA joint consultation paper on benchmarks
More informationICE BENCHMARK ADMINISTRATION CONSULTATION AND FEEDBACK REQUEST: LIBOR CODE OF CONDUCT ICE Benchmark Administration Limited (IBA) is responsible for the end-to-end administration of four systemically important
More informationEU BENCHMARKS REGULATION
EU BENCHMARKS REGULATION NOVEMBER 2017 CONTENTS EU Benchmarks Regulation INTRODUCTION 3 WHO IS AFFECTED? 4 WHICH BENCHMARKS? 7 THIRD COUNTRY BENCHMARKS 9 TIMEFRAME 10 KEY CHALLENGES 12 KEY TERMS 13 YOUR
More informationSTOXX Ltd. Response to Public Consultation
STOXX Ltd. Response to Public Consultation by the IOSCO on Financial Benchmarks Zurich, February 8, 2013 STOXX Limited Selnaustrasse 30 8021 Zurich Switzerland STOXX RESPONSE: IOSCO CONSULTATION ON FINANCIAL
More informationStatement of Compliance with IOSCO Principles TRY Implied. Citibank, N.A. London Branch
Statement of Compliance with IOSCO Principles TRY Implied Citibank, N.A. London Branch October 2016 Introduction: Statement of Compliance Citibank N.A., London Branch ( CBNA ) develops, calculates and
More informationMr. Alp Eroglu International Organization of Securities Commissions (IOSCO) Calle Oquendo Madrid Spain
Mr. Alp Eroglu International Organization of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain Dear Mr. Eroglu: Re: Consultation Report CR01/03 on Financial Benchmarks The Investment Company
More informationEU Benchmark Regulation: Is your transaction up to the mark?
15 EU Benchmark Regulation: Is your transaction up to the mark? Key points the EU Benchmark Regulation is, as of January 1 2018, now in effect, applying to administrators, users and contributors to benchmarks;
More informationImplementing measures on the Alternative Investment Fund Managers Directive: CESR call for evidence
Implementing measures on the Alternative Investment Fund Managers Directive: CESR call for evidence Initial submission by the Association of Investment Companies The Association of Investment Companies
More informationStatement of Compliance with IOSCO Principles. Citigroup Global Markets Limited
Statement of Compliance with IOSCO Principles Citigroup Global Markets Limited June 2017 Introduction: Statement of Compliance Citigroup Global Markets Limited ( CGML ) develops, calculates, publishes,
More informationCFBF A Guide to PRIBOR. Date: October CZECH FINANCIAL BENCHMARK FACILITY S.R.O. ALL RIGHTS RESERVED.
CFBF A Guide to PRIBOR Date: October 2018 2018 CZECH FINANCIAL BENCHMARK FACILITY S.R.O. ALL RIGHTS RESERVED. Contents 1 Part 1 About PRIBOR... 4 1.1 Definition of PRIBOR... 4 1.2 Classification as Interest
More informationDGG 1B EUROPEAN UNION. Brussels, 3 May 2016 (OR. en) 2013/0314 (COD) PE-CONS 72/15 EF 228 ECOFIN 973 CODEC 1710
EUROPEAN UNION THE EUROPEAN PARLIAMT THE COUNCIL Brussels, 3 May 2016 (OR. en) 2013/0314 (COD) PE-CONS 72/15 EF 228 ECOFIN 973 CODEC 1710 LEGISLATIVE ACTS AND OTHER INSTRUMTS Subject: REGULATION OF THE
More informationEU Benchmarks Regulation and Market Impact as of 1 January 2018
EU Benchmarks Regulation and Market Impact as of 1 January 2018 The new EU Benchmarks Regulation (BMR) was published in June 2016 and most rules will apply as of 1 January 2018. The BMR introduces new
More informationThe ICE Brent Index Practice Standards sets out the respective responsibilities of:
ICE Brent Practice Standards Introduction The ICE Brent Index Practice Standards sets out the respective responsibilities of: ICE Futures Europe ( IFEU ) as the benchmark administrator of the ICE Brent
More informationFonds de Compensation FDC SICAV Obligations EUR Actif 3
Fonds de Compensation FDC SICAV Obligations EUR Actif 3 Sustainable Approach March 2018 Amundi Sustainable Approach Sustainable and Responsible Investing has been a long standing and essential part of
More informationCOMMISSION DELEGATED REGULATION (EU) /... of
EUROPEAN COMMISSION Brussels, 13.7.2018 C(2018) 4434 final COMMISSION DELEGATED REGULATION (EU) /... of 13.7.2018 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council with
More informationRecommendation of the Council on Good Practices for Public Environmental Expenditure Management
Recommendation of the Council on for Public Environmental Expenditure Management ENVIRONMENT 8 June 2006 - C(2006)84 THE COUNCIL, Having regard to Article 5 b) of the Convention on the Organisation for
More informationINTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS
Guidance Paper No. 2.2.x INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS GUIDANCE PAPER ON ENTERPRISE RISK MANAGEMENT FOR CAPITAL ADEQUACY AND SOLVENCY PURPOSES DRAFT, MARCH 2008 This document was prepared
More informationConsultation Paper RTS specifying the scope of the consolidated tape for non-equity financial instruments
Consultation Paper RTS specifying the scope of the consolidated tape for non-equity financial instruments 03 October 2016 ESMA/2016/1422 Date: 03 October 2016 ESMA/2016/1422 Responding to this paper ESMA
More informationEFAMA response to the ESMA Consultation Paper on Draft Technical Standards under the Benchmarks Regulation
EFAMA response to the ESMA Consultation Paper on Draft Technical Standards under the Benchmarks Regulation A. GENERAL REMARKS The European Fund and Asset Management Association 1, EFAMA, welcomes the opportunity
More informationREPORT ON INVESTMENT MANAGEMENT INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS
REPORT ON INVESTMENT MANAGEMENT INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS October 1994 PRINCIPLES FOR THE REGULATION OF COLLECTIVE INVESTMENT SCHEMES and EXPLANATORY MEMORANDUM INTRODUCTION
More informationDIRECTIVES. (Text with EEA relevance)
L 87/500 31.3.2017 DIRECTIVES COMMISSION DELEGATED DIRECTIVE (EU) 2017/593 of 7 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council with regard to safeguarding of
More informationICE DATA INDICES, LLC TRANSITION POLICY
ICE DATA INDICES, LLC TRANSITION POLICY December 2017 CONTENTS 1. Introduction... 2 2. Discontinuation of a benchmark (including a currency or tenor)... 3 3. Alternative benchmark(s)... 4 4. Parallel benchmarks...
More informationMr. Alp Eroglu International Organization of Securities Commissions (IOSCO) Calle Oquendo Madrid Spain
Mr. Alp Eroglu International Organization of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain Dear Mr. Eroglu: Re: Consultation Report CR04/03 on Financial Benchmark Principles The Investment
More informationCompliance with IOSCO Principles for Financial Benchmarks (19 principles)
Compliance with IOSCO Principles for Financial Benchmarks (19 principles) March 9, 2017 General Incorporated Association JBA TIBOR Administration The Final Report on Principles for Financial Benchmarks
More informationADVICE TO ESMA. Benchmarks/Indices. Securities and Markets Stakeholder Group. I. Executive summary
Securities and Markets Stakeholder Group Date: 26 February 2013 ESMA/2013/SMSG/03 ADVICE TO ESMA Benchmarks/Indices I. Executive summary Indices are fundamental because they may underpin an investment
More informationDEVELOPING ASIAN CAPITAL MARKETS
The EU Benchmarks Regulation Co-authored by ASIFMA and Herbert Smith Freehills December 2017 DEVELOPING ASIAN CAPITAL MARKETS 1 EXECUTIVE SUMMARY This paper provides a high level summary for non-eu benchmark
More informationConsultation Paper Draft technical advice under the Benchmarks Regulation
Consultation Paper Draft technical advice under the Benchmarks Regulation 27 May 2016 ESMA/2016/723 Date: 25 May 2016 ESMA/2016/723 Responding to this paper ESMA invites comments on all matters in this
More informationPowers in relation to LIBOR contributions
Policy Statement PS18/5 March 2018 PS18/5 This relates to Contents Consultation Paper 17/15 which is available on our website at www.fca. org.uk/publications/consultation/ cp17-15.pdf Please send any comments
More informationERRATUM LETTER TO UNITHOLDERS OF THE MUTUAL FUND AMUNDI ETF NASDAQ-100 EUR HEDGED DAILY UCITS ETF. Paris, 16 August Dear Sir or Madam,
ERRATUM LETTER TO UNITHOLDERS OF THE MUTUAL FUND AMUNDI ETF NASDAQ-100 EUR HEDGED DAILY UCITS ETF Paris, 16 August 2016 Dear Sir or Madam, In your capacity as a unit holder of the mutual fund AMUNDI ETF
More informationOECD GUIDELINES ON INSURER GOVERNANCE
OECD GUIDELINES ON INSURER GOVERNANCE Edition 2017 OECD Guidelines on Insurer Governance 2017 Edition FOREWORD Foreword As financial institutions whose business is the acceptance and management of risk,
More informationUniCredit reply to IOSCO on Principle for Financial Benchmarks
For publication 14 May 2013 UniCredit reply to IOSCO on Principle for Financial Benchmarks UniCredit is a major international financial institution with strong roots in 22 European countries, active in
More informationWorking Group on euro risk-free rates. Guiding principles for fallback provisions in new contracts for euro-denominated cash products
Working Group on euro risk-free rates Guiding principles for fallback provisions in new contracts for euro-denominated cash products January 2019 Contents 1 Introduction 2 2 Current legal frameworks and
More informationQuestions and Answers ESMA s guidelines on ETFs and other UCITS issues
Questions and Answers ESMA s guidelines on ETFs and other UCITS issues 9.01.2015 ESMA/2015/12 Date: 9 January 2015 ESMA/2015/12 Contents Question 1: Information to be inserted in the prospectus 5 Question
More informationPrinciples for Financial Benchmarks
Principles for Financial Benchmarks November 2012 INTRODUCTION Financial benchmarks are widely used as references for determining payments under a variety of financial instruments and many have a significant
More informationREINSURANCE RISK MANAGEMENT GUIDELINE
DRAFT DRAFT REINSURANCE RISK MANAGEMENT GUIDELINE Initial publication: April 2010 Update: July 2013 Table of Contents Preamble... 2 Introduction... 3 Scope... 5 Coming into effect and updating... 6 1.
More informationThe IFRS Foundation s IFRS Conference. Paris, June 2015 KEYNOTE SPEECH: GÉRARD RAMEIX, CHAIRMAN, AUTORITÉ DES MARCHÉS FINANCIERS (AMF)
The IFRS Foundation s IFRS Conference Paris, June 2015 KEYNOTE SPEECH: GÉRARD RAMEIX, CHAIRMAN, AUTORITÉ DES MARCHÉS FINANCIERS (AMF) Ladies and gentlemen, It is an honour for me to speak to such an impressive
More informationDraft for Consultation FICOM ICAAP Guide
Draft for Consultation FICOM ICAAP Guide BC Credit Unions November 2017 www.fic.gov.bc.ca Table of Contents INTRODUCTION... 1 FEATURES OF AN EFFECTIVE ICAAP... 2 I. Board and Management Oversight... 2
More informationClimate Bonds Standard Version 3.0
Climate Bonds Standard Version 3.0 Climate Bonds Initiative 1 Table of Contents The structure of the Climate Bonds Standard had been adjusted to better reflect its consistency and alignment with the Green
More informationTHOMSON REUTERS. Canadian Dollar Offered Rate (CDOR) Contributor Code of Conduct. Issue Date: 8 Jan 2018
THOMSON REUTERS Canadian Dollar Offered Rate (CDOR) Contributor Code of Conduct Issue Date: 8 Jan 2018 Thomson Reuters Document Classification: Public CONTENTS Section 1 Background 3 Section 2 Code of
More informationPrudential Standard GOI 3 Risk Management and Internal Controls for Insurers
Prudential Standard GOI 3 Risk Management and Internal Controls for Insurers Objectives and Key Requirements of this Prudential Standard Effective risk management is fundamental to the prudent management
More informationINTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS
Guidance Paper No. 2.2.6 INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS GUIDANCE PAPER ON ENTERPRISE RISK MANAGEMENT FOR CAPITAL ADEQUACY AND SOLVENCY PURPOSES OCTOBER 2007 This document was prepared
More informationMACRO-PRUDENTIAL ASPECTS OF THE REFORM OF BENCHMARK INDICES
14 November 2012 MACRO-PRUDENTIAL ASPECTS OF THE REFORM OF BENCHMARK INDICES in response to a consultation by the European Commission on a possible framework for the regulation of the production and use
More informationCORPORATE GOVERNANCE CHARTER
CORPORATE GOVERNANCE CHARTER Table of contents PRELIMINARY DECLARATION 3 SHAREHOLDING 4 I. SHAREHOLDING STRUCTURE II. THE GENERAL MEETING OF SHAREHOLDERS THE BOARD OF DIRECTORS 7 I. THE BOARD 1. Principles
More informationQuestions and Answers ESMA s Guidelines on ETFs and other UCITS issues
Questions and Answers ESMA s Guidelines on ETFs and other UCITS issues 11 July 2013 ESMA/2013/927 Date: 11 July 2013 ESMA/2013/927 Contents Question 1: Information to be inserted in the prospectus 5 Question
More informationCAPTIVE BEST PRACTICE GUIDELINES
CAPTIVE BEST PRACTICE GUIDELINES Version 01:01/11 1 Table of Contents 1. Introduction... 3 2. General Governance Requirements... 4 3. Risk Management System... 5 4. Actuarial Function... 7 5. Outsourcing...
More informationContact address: Global Food Safety Initiative Foundation c/o The Consumer Goods Forum 22/24 rue du Gouverneur Général Eboué Issy-les-Moulineaux
Contact address: Global Food Safety Initiative Foundation c/o The Consumer Goods Forum 22/24 rue du Gouverneur Général Eboué 92130 Issy-les-Moulineaux France Secretariat email: gfsinfo@theconsumergoodsforum.com
More informationSTATUTORY INSTRUMENTS. S.I. No. 604 of 2017 CENTRAL BANK (SUPERVISION AND ENFORCEMENT) ACT 2013 (SECTION 48(1)) (INVESTMENT FIRMS) REGULATIONS 2017
STATUTORY INSTRUMENTS. S.I. No. 604 of 2017 CENTRAL BANK (SUPERVISION AND ENFORCEMENT) ACT 2013 (SECTION 48(1)) (INVESTMENT FIRMS) REGULATIONS 2017 2 [604] S.I. No. 604 of 2017 CENTRAL BANK (SUPERVISION
More informationKINGDOM OF SAUDI ARABIA. Capital Market Authority INVESTMENT FUNDS REGULATIONS
KINGDOM OF SAUDI ARABIA Capital Market Authority INVESTMENT FUNDS REGULATIONS English Translation of the Official Arabic Text Issued by the Board of the Capital Market Authority Pursuant to its Resolution
More informationPosition AMF Recommendation Guide to the organisation of the risk management system within asset management companies DOC
Position AMF Recommendation Guide to the organisation of the management system within asset management companies DOC-2014-06 References: Articles 313-1 to 313-7, 313-53-2 to 313-58, 313-60, 313-62 to 313-71,
More informationSOCIÉTÉ GÉNÉRALE COMMODITY-LINKED NOTES PRODUCT SUPPLEMENT
SOCIÉTÉ GÉNÉRALE COMMODITY-LINKED NOTES PRODUCT SUPPLEMENT (To the Offering Memorandum dated March 30, 2017) Payment or delivery of all amounts due and payable or deliverable under the Commodity-Linked
More informationOpinion of the EBA on Good Practices for ETF Risk Management
EBA-Op-2013-01 7 March 2013 Opinion of the EBA on Good Practices for ETF Risk Management Table of contents Table of contents 2 Introduction 4 I. Good Practices for ETF business 6 II. Considerations for
More informationOECD guidelines for pension fund governance
DIRECTORATE FOR FINANCIAL AND ENTERPRISE AFFAIRS OECD guidelines for pension fund governance RECOMMENDATION OF THE COUNCIL These guidelines, prepared by the OECD Insurance and Private Pensions Committee
More informationAMF position ETFs and other UCITS issues
AMF position 2013-06 ETFs and other UCITS issues Background regulations: Articles L. 214-23, R. 214-15 to R. 214-19 and D. 214-22-1 of the Monetary and Financial Code The Autorité des Marchés Financiers
More informationTHOMSON REUTERS. Methodology. Canadian Dollar Offered Rate (CDOR) Effective Date: January 08, Version Date: January 03, 2018
THOMSON REUTERS Methodology Canadian Dollar Offered Rate (CDOR) Effective Date: January 08, 2018 Version Date: January 03, 2018 Thomson Reuters Document Classification: Public Page 1 of 9 CONTENTS 1 -
More informationResponse to Cayman Islands Monetary Authority Private Sector Consultation on Corporate Governance
Response to Cayman Islands Monetary Authority Private Sector Consultation on Corporate Governance 1. Introduction The HFSB welcomes the opportunity to respond to the Cayman Island Monetary Authority (CIMA)
More informationComments on POSITION PAPER ON THE EVOLUTION OF ICE LIBOR issued by the ICE Benchmark administration
December 19, 2014 To the ICE Benchmark administration Japanese Bankers Association Comments on POSITION PAPER ON THE EVOLUTION OF ICE LIBOR issued by the ICE Benchmark administration We, the Japanese Bankers
More informationConsultation Paper Draft technical standards on content and format of the STS notification under the Securitisation Regulation
Consultation Paper Draft technical standards on content and format of the STS notification under the Securitisation Regulation 19 December 2017 ESMA33-128-33 19 December 2017 ESMA33-128-33 Responding to
More informationFinancial Services Regulatory Framework: Advanced Examination
Financial Services Regulatory Framework: Advanced Examination Prepared by Effective from Cyprus Securities and Exchange Commission, Cyprus International Institute of Management, Chartered Institute for
More informationCanadian Dollar Offered Rate Code of Conduct
Canadian Dollar Offered Rate Code of Conduct 1. Background 1.1. CDOR was originally developed to establish a daily benchmark reference rate for Bankers Acceptance borrowings. 1.2. CDOR is now also used
More informationTHE PASSPORT UNDER MIFID
THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS Ref: CESR/07-318 THE PASSPORT UNDER MIFID Recommendations for the implementation of the Directive 2004/39/EC Feedback Statement May 2007 11-13 avenue de
More informationPosted by Martin Liebi and Alexandra Balmer, PricewaterhouseCoopers LLP, on Wednesday, November 1, 2017
Posted by Martin Liebi and Alexandra Balmer, PricewaterhouseCoopers LLP, on Wednesday, November 1, 2017 Editor s note: Martin Liebi is a Director and Alexandra Balmer is a Consultant at PricewaterhouseCoopers
More informationCESR s Issues Paper. Can hedge fund indices be classified as financial indices for the purpose of UCITS?
THE COMMITTEE OF EUROPEAN SECURITIES REGULATORS Ref: CESR/06-530 CESR s Issues Paper Can hedge fund indices be classified as financial indices for the purpose of UCITS? October 2006 11-13 avenue de Friedland
More informationMIFID II Level 2 (draft ) Item 3. Investor protection issues
MIFID II Level 2 (draft 16.04.2015) Item 3 Investor protection issues - Safeguarding of client assets - The legitimacy of inducements to be paid to/by a third person Disclaimer: The information contained
More informationLiechtenstein Law Gazette
Liechtenstein Law Gazette 951.30 Year 2005 No. 156 published on 9 August 2005 Law of 19 May 2005 on Investment Undertakings (Investment Undertakings Act, IUA) I hereby grant my consent to the following
More informationEUROPEAN SECURITIES AND MARKETS AUTHORITY 103 Rue de Grenelle Paris France. Submitted via the ESMA website. 15 February 2013
German Savings Banks Association Charlottenstrasse 47 10117 Berlin Germany EUROPEAN SECURITIES AND MARKETS AUTHORITY 103 Rue de Grenelle Paris 75007 France Submitted via the ESMA website Contact: Dr. Reinhold
More informationRevised Guidelines on the recognition of External Credit Assessment Institutions
30 November 2010 Revised Guidelines on the recognition of External Credit Assessment Institutions Executive Summary 1. The Capital Requirements Directive 1 (CRD) allows institutions to use external credit
More informationCMC Europe position paper: proposed Benchmarks Regulation
CMC Europe position paper: proposed Benchmarks Regulation 1. CMC Europe considers it essential that the scope of the proposed Benchmarks Regulation is clear and understood and encourages policy makers
More information- To promote transparency of derivative data for both regulators and market participants
5 August 2012 Broadgate West One Snowden Street London EC2A 2DQ United Kingdom European Securities and Markets Authority Via electronic submission DTCC Data Repository Limited responses to ESMA s Consultation
More informationFrance Takeover Guide
France Takeover Guide Contact Youssef Djehane BDGS Associés djehane@bdgs-associes.com Contents Page INTRODUCTION... 1 KEY HIGHLIGHTS... 1 REGULATORY ISSUES... 3 PREPARING THE OFFER... 4 FILING AND CONDUCT
More informationConsultation on Term SONIA Reference Rates Summary of Responses. The Working Group on Sterling Risk-Free Reference Rates
Consultation on Term SONIA Reference Rates Summary of Responses The Working Group on Sterling Risk-Free Reference Rates November 2018 Term Sonia Reference Rates Consultation - Summary of Responses 1 The
More informationConsultation Paper. ESMA Guidelines on the application of the endorsement regime under Article 4 (3) of the Credit Rating Regulation 1060/2009
Consultation Paper ESMA Guidelines on the application of the endorsement regime under Article 4 (3) of the Credit Rating Regulation 1060/2009 18 March 2011 ESMA/2011/97 Date: 18 March 2011 ESMA/2011/97
More informationThe DFSA Rulebook. Authorised Market Institutions (AMI) AMI/VER16/06-14
The DFSA Rulebook Authorised Market Institutions (AMI) PART 1: INTRODUCTION... 1 1. APPLICATION, INTERPRETATION AND OVERVIEW... 1 1.1 Application... 1 PART 2: APPLICATION AND AUTHORISATION... 3 2. APPLICATION
More informationConsultation Paper Handbook changes to reflect the application of the EU Benchmarks Regulation
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax ihsmarkit.com Financial Conduct Authority 25 The North Colonnade London E14 5HS
More informationLYXOR ANSWER TO THE CONSULTATION PAPER "ESMA'S GUIDELINES ON ETFS AND OTHER UCITS ISSUES"
Friday 30 March, 2012 LYXOR ANSWER TO THE CONSULTATION PAPER "ESMA'S GUIDELINES ON ETFS AND OTHER UCITS ISSUES" Lyxor Asset Management ( Lyxor ) is an asset management company regulated in France according
More informationMaster Class: Index Regulation and Outsourcing Index Administration
Master Class: Index Regulation and Outsourcing Index Administration Thursday, July 28, 2016 8:30 a.m. 9:30 a.m. Morrison & Foerster LLP 250 West 55 th Street New York, NY 10019 Speakers: Lloyd Harmetz,
More informationBERMUDA INSURANCE (GROUP SUPERVISION) RULES 2011 BR 76 / 2011
QUO FA T A F U E R N T BERMUDA INSURANCE (GROUP SUPERVISION) RULES 2011 BR 76 / 2011 TABLE OF CONTENTS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Citation and commencement PART 1 GROUP RESPONSIBILITIES
More informationMSCI REAL ESTATE INDEX CONSULTATION
MSCI REAL ESTATE INDEX CONSULTATION Should MSCI seek authorization in the EU as an administrator for MSCI asset-based and fund-based real estate indexes? April 2018 Within this document, MSCI real estate
More informationConsultation Paper No. 7 of 2015 Appendix 4. Abu Dhabi Global Market Rulebook Market Infrastructure Rulebook (MIR)
Abu Dhabi Global Market Rulebook Market Infrastructure Rulebook (MIR) Contents 1 INTRODUCTION... 1 2 RULES APPLICABLE TO ALL RECOGNISED BODIES... 2 2.1 Introduction... 2 2.2 Suitability... 2 2.3 Governance...
More informationBEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS
BEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS APPLICABLE TO SOCIÉTÉ GÉNÉRALE ENTITIES IN THE EUROPEAN ECONOMIC AREA (Head office, Branches, and Subsidiaries) Version
More informationHPV Health Purchasing Policy 1. Procurement Governance
HPV Health Purchasing Policy 1. Procurement Governance Establishing a governance framework for procurement 25 May 2017 1 Health Purchasing Policy 1. Procurement Governance Health Service Compliance Health
More informationBENCHMARK STATEMENT - LBMA GOLD PRICE AND THE LBMA SILVER PRICE
BENCHMARK STATEMENT - LBMA GOLD PRICE AND THE LBMA SILVER PRICE 1. Introduction ICE Benchmark Administration Limited (IBA) is the Benchmark Administrator of four systemically important benchmarks: ICE
More informationSelection and Execution Policy
Selection and Execution Policy April 2015 SELECTION & EXECUTION POLICY Purpose This document describes how selection and execution policies are established when Amundi carries out its portfolio management
More informationEFAMA response to the ECB s first public consultation on developing a euro unsecured overnight interest rate
developing a euro unsecured overnight interest rate A. Preliminary comments The European Fund and Asset Management Association, EFAMA 1, welcomes the decision of the ECB to consult market participants
More informationStatement of Guidance for Licensees seeking approval to use an Internal Capital Model ( ICM ) to calculate the Prescribed Capital Requirement ( PCR )
MAY 2016 Statement of Guidance for Licensees seeking approval to use an Internal Capital Model ( ICM ) to calculate the Prescribed Capital Requirement ( PCR ) 1 Table of Contents 1 STATEMENT OF OBJECTIVES...
More information2018 SUPERVISORY PRIORITIES FOR THE AUTORITÉ DES MARCHÉS FINANCIERS
2018 SUPERVISORY PRIORITIES FOR THE AUTORITÉ DES MARCHÉS FINANCIERS In accordance with the guidelines published in its 2018-2022 strategy, and as a supplement to the associated 2018 priority actions,
More information