GFMA, FIA, and ISDA submitted a joint comment letter to the ESMA consultation on draft guidelines on non-significant benchmarks under the BMR. While supportive of the broad goals of the BMR to provide a harmonized regulatory framework for non-significant benchmarks in the EU, comments emphasized the need for greater proportionality in several aspects of the draft guidelines. The trades recommended that ESMA should eliminate or reduce some of the requirements of the draft guidelines, to achieve a more proportionate, principles-based and balanced approach, particularly where the draft guidelines covers obligations similar to those which are not applicable to non-significant benchmark under the BMR.
