 Next on the agenda is the working group of experts that will guide us through the two consultations on URIBOR fallbacks. And as mentioned at the start, there will be an opportunity for questions afterwards. I will therefore now give the floor to Adolfo Fraguas, he is the head of the legal department at BBVA Spain and he's also chair of the subgroup on contractual robustness of the working group on risk-free rates. And he will explain the working group's main proposals with regards to URIBOR fallback trigger events. Adolfo, the floor is yours. Thank you. Hello everybody. Well, we are going now to talk about the public consultation on URIBOR fallback trigger events. But first, perhaps we need to make an effort to answer a question which would be necessary. And the question is, why does the market need URIBOR fallback provisions? If we move to the next slide, please. I think that we are all here aware that critical benchmarks are undergoing significant reforms. We are not going to enter into the reasons for these reforms. They are all well known and have already mentioned by my previous colleagues. But I think that it is worth mentioning three main milestones that have all of us come to this point in this process. The first would be the IOSCO principles for financial benchmarks. They were issued in 2013 and they were recommendations for administrators and submitters of quotes for benchmarks. These recommendations were mainly in terms of governance on the quality of the benchmark, the methodology, the accountability, at the end of the day, on the increase of the credibility of the benchmarks. The second milestone was the FSB, the Financial Estability Board, recommendations on reforming major interest rate benchmarks in 2014. And the purpose, the objectives of this document was twofold. First, it was to strengthen the way in which existing benchmarks were calculated in order for them to be based on transaction data as much as possible instead of other alternatives such as quotes, either firm or not, expert judgment or whatever. The second objective was to encourage the market to develop alternative, nearly risk-free reference rates. With the purpose to complete and if necessary, substitute existing benchmark effort rates. And I think that all this has been successfully achieved. The strength of the arrival was completed in 2019. I will refer to it a little bit later. And in terms of risk-free rates, we can congratulate ourselves to have already, in the main currencies, risk-free reference rates. For instance, with the US dollar we have so far, with the Stirling, we have Sonya, and here in Europe, we have the EuroSDR. And the third milestone would be the benchmark regulation, the European Union benchmark regulation enacted on 2016, which came into force in January 2018. This is for sure a major milestone, with I think no equivalence in the world. And at the end of the day, it stated that supervised entities and supervised entities refer to what benchmark regulation refers, that is banks, investment firms, asset managers, insurance companies and the like, supervised entities in order to continue using those benchmarks that were being used until this point in time, in contracts and financial instruments, need to have this administrator of this benchmark nearly authorized before the authorize. And this authorization is the result of a tough evaluation of the compliance of the requirements of the benchmark regulation, which as I have said, are very, very significant. So all these came to a point in which, as Yosco and BMR were encouraging, resolved in a recommendation in the need to introduce robust fallbacks in contracts in order to tackle the possible seismic of an index. So all these driver and in terms of benchmark reform came to a point in which it was clear that we need to introduce robust fallbacks if we didn't already have them in our contracts. If we move to the next slide, please. This is what happened with the benchmark regulation in article 28.2. This legal need for Euroval fallback provision was therein included and it stated that supervised entities are required to produce and maintain robust written plans, which will foresee what to do in the event that a benchmark is seized or materially changes. And it included an obligation to include an alternative benchmark if the previous one was seized, no longer provided. And if this alternative benchmark was feasible and appropriate, there is one to include. But on top of that, the benchmark regulation also required all the supervised entities to provide upon request of the authorities these written plans to them, to the competent authorities. And also, which is completely reasonable, to reflect these written plans in their contractual relationships with clients. And this is reasonable because at the end of the day, the objective of these robust written plans have to be translated into the private relationships in order to include the outcome of these robust written plans expected to be set out by the supervised entities. And the main purpose of all this was to reduce legal uncertainty, to avoid the possibility of illegal dispute. Because as we all know, if the benchmark that we are using, which is normally the mean to calculate the contribution by one party to the other, or the price of the contract disappears, it would create not only uncertainty, but for sure disputes. One party could argue and advocate for the continuation of the contract. The other party could advocate for the determination, the determination of the contract. The one advocating for the continuation will have to discuss which would be the new reference to be used if it has not already been agreed in the past and so on and so forth. But perhaps in order to have all the concepts clear, we can move to the next slide, we could stop a little bit in order to make for all the audience clear what the fallback provision is and what are its main elements. A fallback provision is a contractual clause, agreed among the parties that determines what is the rate that will apply in a certain point in time if they initially agree one is not available anymore. So as I have mentioned, without these fallbacks, legal uncertainty, disputes and problems will arise. And what are the elements of a fallback provision? Mainly four. First, the trigger event. The trigger event is the event that activates the substitution of the old rate by the new one, by the fallback one. The second is the fallback rate, which is the new rate, the new benchmark that is going to be used in substitution of the old one, the one that is not available anymore. On addition to this fallback rate, we will need an spread adjustment. The idea is that this spread adjustment, either adding something to the fallback rate or subtracting it, will maintain the economic value of the contract, will make both the old rate and the new one equivalent. And will, at the end of the day, avoid the transfer of value, meaning one party being benefiting with this fallback rate in case of being substituted and the other one being prejudiced about value. And finally, we have to agree in this contractual provision, this fallback provision, the effective date of the fallback rate, when it will be really applicable once the trigger event has been activated. So if we move to the next page, despite the legal need to have these written plans, and unlike all the arrivals, I think that we have to congratulate ourselves because we can affirm that the arrival is not scheduled to be discontinued. The arrival has been experienced in reform that has already been mentioned previously, in order to meet the benchmark regulation requirements, basically in two major aspects. First, strengthening its governance framework. It has been involved, the code of conduct has been involved. There is a need for auditing. There are many new obligations for contributors. That have made more robust derives. And additionally, there has been a development of what is called the hybrid methodology in order to permit the arrival of being based on your money market transactions. This is, as Stephen Major has just mentioned, what has made it more robust, resilient, and transparent. So this came to a point in which the authorization of the administrator and therefore the index was achieved on July the 2nd, 2019 by the Financial Services and Markets Authority, the Belgian Authority, under Article 34 of the MR. This authorization is very important because it permits all supervised entities to continue using your arrival from this point in which was approved onwards. Otherwise, in one year time, we will have a major problem if it hadn't been authorized because the index, your arrival, wouldn't be able to be used anymore. So this risk has been avoided. And I think that we have to congratulate ourselves of the final goal of this process. But besides, we think that it's important to mention that all this ecosystem has also, and thanks to the benchmark regulation, some precautionary measures on supervisory powers that permits us affirm that the risk of substitution being made is minimized, at least as much as possible, even though we cannot rely only on these precautionary measures or supervisory powers. There are mainly three. First, mandatory contribution. This is the possibility for the authorities to compel the contributors, the old ones or new ones, to contribute to the index when the representativeness of a critical benchmark is put at risk. The second one is the mandatory administration. It reflects the possibility to compel an administrator to continue administering a benchmark in case that it intends to cease providing the benchmark, at least until a new administrator is nominated, the index is listed orderly, or it is no longer critical. And finally, there is a possibility also by the authorities to require the administrator to change the methodology, also in order to make the index representative of the underlying test in case that this representativeness would be at risk in a critical benchmark. So in order to summarize all that I have been mentioning, the arrival is not scheduled to be discontinued. These are for sure good news for everybody, but however, we need to include fallback provisions in our relationships among counterparties. First, because we are prudent and we have to avoid the legal uncertainty and disputes coming from an eventual possibility to have a benchmark ceasing and not having a substitute for it. And second, because we have to comply with Adiosco principles and more importantly, with the benchmark regulation with article 28.2, the one I have mentioned before. So after this perhaps long introduction, we can go to what really is the subject of this part of the round table, which is the public consultation on the arrival of fallback trigger events. Next slide, please. And the next one. So first, let's try to clarify what is the objective of this public consultation. The objective is to identify and propose some potential trigger events that would activate your fallbacks. These potential events are presented before the public or the stakeholders in order for them to opine and to give us their feedback on whether they should be included in the recommendation of the trigger events of fallback provision or not. For sure, any participant in the marketplace will decide afterwards what to do. They are free to agree with their counterparties whether to include or not any of these trigger events in their fallback provisions. And therefore, there is no compulsory measure in all these processes. Some general considerations that I think are important before going one by one with the trigger events. First, trigger events should be drafted in precise and objective terms. This is clear. In order to have trigger events that will not raise debate discussions among parties, they have to be very objective. The more precise they are, the less disputes counterparties will face. And ideally, it would mean that there should be no need for the consent or for the debate between the parties in order to determine whether the trigger event exists or not. Second, trigger events should be based on events made public. So it's very important that these trigger events are detonated when the information is known by all the marketplace. It should never be triggered by an informal conversation or by a statement which is not of the public domain. In terms of the effectiveness date of the substitution, we have to differentiate in the date in which the trigger event happens and the date in which the fallback rate starts to be applied. And this second one should only occur once the discontinuation of the initially agreed benchmark arrival has occurred, not in the date in which the public statement was shared among the stakeholders, mainly because it would make all counterparties available to be prepared to the substitution. And therefore, this effectiveness date will imply that only after this effective date, the next interest period should be the one in which the new fallback will apply. And it doesn't seem very, very reasonable to modify the interest rate in the middle of that period of interest. If we go to the next slide, and in terms of the scope of the public consultation for main considerations that are relevant, first, the public consultation covers all asset classes. And the idea would be that these trigger events on which we are asking stakeholders to buy none would be common for all asset classes. This would avoid inconsistencies and mismatches, and therefore, would be of great help. We, the corporate working group already said on October 29 voted, the working group highlights possible risk management implications of one, having timing inconsistencies in fallback provisions triggers, and second, incorporating different fallback triggers language for different asset classes. So we encourage all the participants to try to come to a common point in the definition of the trigger events in order to avoid these inconsistencies. Second of these considerations about the scope, the consultation paper is focusing on the permanent discontinuation of your rival. It is not focusing on any potential temporary unavailability. On any potential computer failing failure, which impedes the benchmark to be published during some days. This is not the object of the consultation. We are also always thinking in a permanent discontinuation. Third, we are in the consultation paper for seeing the discontinuation of all your rival tenors, not just one of them. In fact, the discontinuation of some tenors have already taken place, and with no major issues. Normally, counterparties had agreed to use interpolation in order to solve the situation. Fourth, the consultation paper acknowledges the recommendations made by the international board, is the May afternoon. And finally, you will have to bear in mind that this consultation paper was drafted, was prepared with a precise legislative framework in which the current reform, which Tillman has just explained to us, was not finalized. So we welcome the proposal to amend the benchmark regulation with the purpose to make possible for the commission to designate a replacement benchmark. In certain cases, when there is no appropriate fallback, it could be a risk of financial stability. But as Tillman has said, and I think we all agree on, this should be a solution of last resort. It's a safety net, as Tillman has said. There is no guarantee that it will be used. And therefore, we do, the working group, to recommend fallbacks to be agreed between partners rather than relying on legislative solutions. So the next slide, here you have, next slide please. Here you have in this chart, very summarized, the consultation paper. You can see in the first column in different colors, the views of the consultation paper on the inclusion, green, or the exclusion, red, of certain trigger events. The orange one has its own explanation that we will enter into at the end of the presentation. You have the description of the event, if it requires a public statement, if the public statement is issued, who is the issuer, either the supervisor or the administrator, and what is the eventuality occurring to the event, to the arrival in the last four columns. If it is the cessation of the arrival, this is a matter of non-representativeness, the use of contingency plans by its administrator or a matter of illegal. So if we go to the first one, the first one is a public statement made by the supervisor of the administrator of the arrival, stating that the administrator has this or will cease to provide the arrival on a permanent basis. So three main points, public statement made by the supervisor and referring to the to the assessment of the of the publication of the index. It has to be understood that this trigger event will occur only after any potential mandatory administrator measure have been taking place, as we have been mentioning before. This public statement has to be an official one by FSMA or afterwards by ISMA, and therefore it's not a mirror speech or a particular private statement. It has to be in the public domain. And it is a trigger event, which is somehow included in the BMR reform, or at least in them in the drafts that we have that have been made public. It's in line with ISDA recommendations and also with the Alternative Reference Rate Committee, the ARC, and the US. The second trigger event is more or less the same with just one difference. In this case, the public statement instead of being issued by the supervisor is issued by the administrator of the arrival, Laien. So here again, like in the first case, it's a trigger event that is contemplated in the first drafts of the reform of the BMR regulation. And also it's aligned with ISDA solutions and the ARC recommendations. The third one, which is the so-called presentation trigger event, is the public statement made by the supervisor. In this public statement, the supervisor states that the arrival will state that the arrival is no longer represented or will no longer be represented. It is called a presentation trigger event because it takes place before the season of the index. This trigger event will then take place at the same time of the arrival still being published. It is supposed to be activated after any mandatory contribution being compiled and after any change in the methodology being made as foreseen in the Benchmark regulation. It is also recommended by the ARC in the US and it is included in this documentation for LIBOR but not for URI. Here again, it's an event which is covered in the drafts that we have seen, the public drafts of the Benchmark regulation reform. Now we go to the fourth case. The fourth case is the case in which the administrator of URIBOR, EMI, in this case, determines that URIBOR should be calculated in accordance with its reduced submissions or contingency or fallback policies. Again, it's a precession event because URIBOR is still being published and it is foreseen for a case in which some contingency measure is necessary for the continuity of URIBOR and is adopted by the administrator. In this case, we are not in a case in which the representativeness of the index of the Benchmark of URIBOR is at risk because if that were the case, we would be in trigger event number three. Here the representativeness is not at risk. This is the reason why we are of the view and are asking the stakeholders to opine on the agreement with the proposal of not including this event as a trigger event. It is not included by the ARC in the US recommendations. The fifth one is the illegality one. It is a trigger event that would be activated when it has become, for any reason, unlawful under any applicable law or regulation for a relevant party to continue using URIBOR. Not only because of the applicability of article 35 of the Benchmark regulation, the one that regulates the suspension or withdrawal of the authorization of an administrator of an index, even it could be also triggered for illegality being applicable to other parties due to other regulations, other applicable laws. So here the important thing is to determine who should be this relevant parties that in case of being affected by this illegality trigger event could determine the substitution of the fallback. It is clear that in bilateral loans or in derivatives, if either the borrower or the lender in the first one or for one of both counterparties in the derivatives world becomes illegal to use URIBOR in a particular contract with URIBOR is being used, this seems that should let the contract to have the fallback provision being triggered. But in syndicated loans, for instance, the situation could be different. The potential illegality of using URIBOR for one of the lenders could be solved just with prepayment of this lender amount length instead of forcing on the contract to substitute the Benchmark by applying the trigger event. And in these ones also it's clear that if an investor has a problem and a legality problem in terms of being investing in a particular bond or node, because of this bond or node being referenced to URIBOR, this shouldn't be used as a trigger event of the substitution of the reference rate of URIBOR in the bonds or in the nodes and all the issuance. By the contrary, it most likely be a trigger event of the fallback provision if it affects the issuer or the agent. So the sixth one is the catch all event, an event of last resort. It is the one applying in case of the URIBOR permanently no longer being published. So it is difficult to think in a situation in which this could occur without any of the previous trigger events having taken place. But as a matter of prudency, we consider that this trigger event could be recommended just in case that something has not been foreseen and in case that some scenario has not been captured by the rest of the trigger events. And finally, we have the material change of URIBOR method. And this is a special one because if you remember what I have mentioned about article 20.2, the written plans have to foresee this case. But it is also true that the need to foresee alternative rates is in article 28.2 only applicable to the case in which the rate disappears, something which is not the case here in just the material change of the methodology. On top of that, we have to recall that article 5.3 of PMR requires to the administrator to review on an annual basis the methodology of the index and that this change of the methodology has a clear purpose to prolong its life. Taking apart the discussion on what material or not material means, the point here is that the material change or the non-material change of methodology in the opinion of the public consultation should not be understood as an automatic trigger event. The way to tackle it instead of it of this automatic application is either by parties acknowledging that URIBOR may material change material change and that URIBOR after this change will still be URIBOR will still measure the underlying market, the same reality and therefore that has to continue being the benchmark of the contract. And second option for the parties, which is the one, the second one adopted by LMA, is that instead of being an automatic trigger event, it could be an option for parties to discuss whether to substitute or not the existing benchmark URIBOR. So we leave it open to the stakeholders to combine on the way in which they would prefer to apply this trigger event but have to insist on it. We are not presenting it as an automatic trigger event but as in any case either an acknowledgement of URIBOR continue being the applicable rate which by the other way perhaps is not even necessary in legal terms or alternatively to use it as a possibility to enter into discussion among parties on what to do. So I think that this is a brief summary of the public consultation. In the next slide you have the exact questions that, precise questions that are included. I will like to finalize and question all the stakeholders, all the marketplace to opine to give us their feedback and to give us their opinion on how the working group should recommend to include or not these trigger events. Thank you very much. Now I think that William will... Yes, thank you. Thank you Adolfo. Thank you for... Oh wait, sorry I had an issue with connecting so I needed to switch off my camera briefly. Thank you Adolfo. We are now going to the Q&A session. You see on the screen how you can ask questions and the screen also shows and that saves me from having to mention it to you but you can see on the screen is the colleagues, the other experts that are available for us to answer questions and to kick things off. I would like to start with a question to Cam Mayhill of the LMA and to Rick Sandilens of the ISDA. Namely, your organizations have also defined trigger events and contract templates for the derivatives and loan markets. How do they align with these proposed URIBO fallback trigger events? Cam or Rick, who of you would like to start? Hi William, it's Cam. Can you hear me properly? Excellent. I'll start first and then hand over to Rick. I think it's important just to flag that there are a couple of LMA documents that are mentioned within the consultation paper and they actually operate very differently and have slightly different triggers. So it's important to be clear which LMA document you're looking at. So the first document that's mentioned in the paper is the replacement of screen rank language which actually isn't really fallback language at all. As Adolfo says it involves triggers for a negotiation process. So as a result the triggers we have in that clause are wider than fallback triggers because there's no automatic consequence of those triggers. So the other document to consider from the LMA perspective which is more in line with what this consultation paper covers is the rate switch agreement which we published in September and which has been updated in November where triggers do lead to an automatic switch from an eyeball to risk-free rates. So I think the rate switch agreement is probably the document that people should have in mind when thinking about the trigger events in the consultation paper. And I would say for the rate switch agreements we've broadly aligned the triggers with what's in the ISDA fallbacks which Rick will touch on but essentially we've included the triggers for cessation and pre cessation events in line with those outlined in 1-3 that were on the slides that Adolfo was presenting. And the approach we've taken to the trigger events is aligned with that in the consultation paper which is that trigger event should be objective and clearly defined. I would say that the one place where we differ from the proposals in the consultation paper is the unlawfulness trigger which isn't included in our documentation but that's for precisely the reasons that Adolfo mentioned. I think that you know in that case our documents really are broadly designed for the international market so not just focusing on the Eurozone and given the way that the BMR impacts indicated loans but also being conscious of the issues that are outlined in the consultation paper about unlawfulness triggers and interactions with illegality provisions that are contained in loan agreements. So that's one that's not included specifically in our documentation but it is outlined in the commentary that we've produced for parties to consider depending on the circumstances but also to think about provisions that are in the BMR on eyeball transition as well. So I think at that stage I'll hand over to Rick to talk about the ISDA triggers. Thank you Cam. William hopefully you can hear me too. Yes excellent. Great hello everyone. Yes I think the answer to your question is that the fallbacks do broadly align with the fallbacks that ISDA has published. I'll just step back back one moment to talk about the documents that we've published because there are a couple of sets that are easily confused and it's important that people have them separated in their mind. So the most recent documents which are relevant to this are the ISDA eyeball fallbacks supplement and protocol. They were published back in October and there's a process at the moment to allow people to adhere to our protocol which will allow them to embed these fallbacks into their legacy transactions but that protocol itself won't become live, go live until the 25th of January and so we're around a month away from the go live period for that protocol. That's also the date on which the supplement will go live and that will have the effect of incorporating these fallbacks into new transactions and so you'll have an alignment between your new and legacy transactions provided you adhere to the protocol. Adherence to the protocol is voluntary so you do need to take steps in order for that to occur and the triggers which are set out there very much in line with what Cam was saying and what you were saying in terms of ensuring that there's clarity and consistency, the triggers are objective and publicly verifiable. There are two cessation triggers which are a cessation is announced by the administrator or a cessation is announced by the supervisor of the administrator. One of the differences you'll see between the ISDA fallbacks triggers and those that are set out in this consultation is that we have a broader array of regulatory and official authorities who can make that announcement and still effectuate the second trigger so it could be an insolvency authority for that benchmark administrator. But I think the much more likely scenario would be that it would be the regulator of the administrator or the benchmark who made that announcement. Critically one really key difference is that the iBOR fallbacks that ISDA has published do not include a non-representativeness trigger so that third trigger that you can see in the list that Adolphe went through is only included for iBOR benchmarks so for Euro iBOR for example there is a non-representativeness trigger and it broadly aligns with the non-representativeness trigger set out here but for your iBOR there is not one and that's because ISDA held a consultation with the public on whether or not to include a non-representativeness trigger and there was no consensus on doing that. We subsequently launched a second consultation on that question but just for iBOR because the information that had been released to the market by CCPs and regulators around their actions with respect to iBOR had been updated and there was new information in the market which made that non-representativeness trigger I think more logical for the derivatives market that was not the case for your iBOR for example or the other iBORs and so that is not included. Just going down to the seventh of those entries on the consultation talking about material change being made to an iBOR that's something which the iBOR fallbacks deal with by acknowledging that that might happen you may remember that your iBOR for example changed its methodology very recently Ionia similarly changed its methodology very recently benchmarks nowadays evolve at quite a rapid rate and therefore I think the feeling within our working groups was that it was better to acknowledge that that would be the case and for the transaction to continue referencing the benchmark using that new methodology rather than having a fallback triggered at that point which could you know if you think about your iBORs change in methodology it would have been very disruptive at that moment in time to have fallen back and ISDA's documentation is capable of being tailored so if a change of methodology is in fact very important to you that it's always possible to bilaterally agree to include a fallback on change of methodology as well. Just to finish up the second set of documentation I referred to is ISDA's benchmark supplement and protocol which was published in 2018 that was in response to the European benchmark regulation but that's a generic set of fallbacks they're designed to work alongside or underneath the iBOR fallbacks there's a huge amount of information on our website www.is.org so I'd encourage people to go there for further information thank you William. Thank you so much Cam and Rick next question I have is for Mikkele and I will combine it with a question from the audience the question is Mikkele of Esma when do you expect action from supervised entities to actually include these fallbacks into contracts and if I may combine a question of Emilio sorry Emilio Gamara he is asking whether the URIBO data that Esma will publish whether this will be made available on the Esma website for free. Mikkele the floor is yours oh I understand now that Mikkele has not joined that means that I cannot ask that question but I'm pretty sure that this information will be made available for for nothing as public authorities usually do so then that means I will go to the next question do banks this is a question from Ivo Martinolli do banks need to activate immediately the fallback rates for contracts with URIBO or only after the consultation is finished maybe Adolfo could answer that question or if he prefers to give the question to someone else Adolfo all right yes I was having problems with the new time mute well I think that the the recommendation to include fallbacks in the contracts is already being issued at different points in time we have already mentioned also article 28.2 so I think that is something that should be done as soon as possible we are trying to help the market with this set of recommendation that we expect to issue in the future with these three events but at the end of the day these three events just recommendations are perfectly being manageable by by counter parties on their own without the need of the public consultation and can be agreed and we recommend them to agree on them as soon as possible even if it were the case not waiting for the outcome of the consultation so I think that it is important if parties have clarity on what they need to cover that they are that they start to do. Thank you very much Adolfo. Next question I have is for let me see I'm a bit lost at the moment a question from Michael Schneider how do you see the probability of using the fallbacks for URIBO because the URIBO panel which currently consists of 18 banks may become too small to be relevant this Adolfo who would you like to give this question to? Well I think that first of all we have to recall something that was mentioned in the presentation that URIBO has both its methodology its governance and it's now a benchmark that can be qualified as a different measure as said today as a robust resilient and transparent benchmark so I don't think that banks should be interested in giving up being contributors in fact I invite all the financial sector to contribute and to join the panel banks in order to to re-robust what we already have as a robust arrival so this is the the first thought I would make and second if for whatever reason the number of panelists were reduced we already have the possibility for the authorities to apply the mandatory contribution and we also have before this step which is a tough one perhaps but we have before the possibility for the administrator to apply the contingency plans as we have said and if we recall number four of the trigger events that we were discussing we consider that it was perhaps a recommendable not to include this applicability of the contingency plans as a trigger event because the application of these contingency plans do not mean that the URIBO would be no longer representative and the importance here I think that has to be focused on the representativeness of URIBO so I think that we should wait in case that any of these contingency plans take place and if the representativeness is assured I think that the idea of the consultation paper is not to include such a situation as a trigger event okay the next question is an easy one because Eleni Christodoulidou is asking whether we will make the presentations available on the on the website and the answer to that is yes then the next question I am going to take and let's me check the time because what time do we have we still have about 10 minutes the question is what is the main reason that URIBO as opposed to other IBO rates is not discontinued this is a question by Juris Le Flemme who would like to answer this question well I don't know if as my it's not here I don't know if yes we can hear you I don't know who is speaking but excuse me this is Mihere Mazzoni from Esma I have some technical issues I'm not on your back guys we miss you thank you it's the beauty of a virtual maybe we do we first do the question I just asked and then we have a few questions for you Mihere I don't know if you can see me now yeah very well so I will flip the question and say that a LIBOR is about has been the process of discounting LIBOR and formally started as we know but in many parts of the world the multirate approach that visage by the working group and european institution in europe of maintaining a LIBOR rate like a LIBOR while at the same time developing a new risk-free rate in our case ester has been taken by many jurisdictions australia canada and i can continue LIBOR is the exception in my view because it's the most important it's published in five currencies it's usually in five continents is the most tricky situation and the one that makes the news because it's the most important especially the US dollar LIBOR as we know but if you look at the documents of the financial stability board where many jurisdictions are covered the vast majority Japan among others took a multirate approach where new risk-free rates are developed in parallel to the existing LIBORs rate thank you thank you Mihere maybe while while I have you can you also confirm that esmar will publish the your LIBOR rates on the website and that everybody can use it let's say for free now I can answer not to this question the administrator of LIBOR as you know is a european money market institute the MMI has been as Steven said authorized by the Belgian FSA and is the owner of LIBOR Esma starting first in one year first january 2022 will be the supervisor of LIBOR so we'll ensure that the LIBOR is a representative of the underlying market and continuously comply with the MR but the administrator of LIBOR will stay the MMI which is also you know the current administrator of EONIA okay so ignore what I said about this this topic and maybe maybe you can also answer the other question when do you expect action from supervised entities to actually include fallbacks into contracts I mean when is this starting is this how soon it's a tricky question because from a regulatory standpoint article 282 that require in particular european supervised entities to implement what we call fallback provision in contracts has been applicable since first january 2018 we know the implementation has been slow also because with reference to the LIBOR the work of the working group was ongoing there were already some general principle and guidance by the LIBOR and sorry by the working group on the LIBOR fallback and we know that the number of participants started implementing those general principles in their contracts now that we are approaching the very ultimate recommendation by the working group that is the precise arrival of fallback rate that triggers event and spread adjustment we would expect next year that european entities follow very closely and quickly these these recommendations so in the course of next year what I can tell you is that I believe together with national competent authorities we will take supervised reaction to ensure that the recommendation of the working group is follow-through in a timely manner thank you very much I'm I can take a question by Christoph Christoph Nala at Tillman I see that Tillman Lüder has already answered it in writing very briefly but maybe he can elaborate a little bit and the question is why does the consultation not address a partial discontinuation scenario where only some but not all tenors of URIBOR are discontinued would be helpful to hear Christoph Nala thinks it would be helpful to hear the working group's views on this topic Tillman yes yes thank you very much so the issue is that all of these interest rate benchmarks are in reality a bundle of individual benchmarks if you take the most obvious example LIBOR it has five currencies and within each currencies it has at least four tenors and so that would give you basically 20 benchmarks and it's the same for URIBOR it only has one currency but it has an overnight one month a three months a six months and a 12 months tenor so you already got five distinct benchmarks and because this is a panel bank benchmark you could easily imagine a situation where panel banks withdraw from one of the tenors because they don't have data or they don't think it's relevant anymore but they continue some of the other tenors most likely of course is that you keep the shorter tenors so the overnight the one month and the three months but maybe you're not so keen anymore not being any more than six months and then each benchmark will have to be dealt with individually and that's why the consultation never talks about URIBOR as one benchmark but essentially it is each tenor may or may not be discontinued independently of whether the other tenors continue and you'd have to look at that per tenor and in LIBOR's case it's even more complicated you have to look at it per tenor and per currency thank you let me ask thank you Tillman and I think we can give you also the final question and then we have a short break Rafaela Bonadius is asking will the commission confirm the modification to IFRS as to the heading definition so as to look basis basis sorry basis swaps it's so by when I'm not I don't understand the question but I hope you do Tillman I can I can I can vaguely kind of guess where this is getting at but I have to disappoint you because I'm responsible for securities markets and IFRS is my colleague so if you want to send me the question in the chat I will forward it to my IFRS colleague yeah maybe it's anyway good that you mentioned this because what we will do with the questions that we are unable to answer is we will we will try to follow up with them in in writing and and possibly add them to the Q&A document that we have so I would like to end this panel here and then we have a short 15 minute break and then I hope to see everyone back at 16.35 at the latest thank you