 So good afternoon everybody. Thanks for joining again. So we will continue now with a panel on term rates initiatives And I'd like to welcome again Yav Keis from ING and Alberto Lopez from EMI and then I have here to my left Dominique Limasson from BMP Paribas, also Sistinia coordinator for European market infrastructures and sharing BMP is sharing one of the subgroups of the working group on term rates Then we have next to her Mikaela Mazzoni senior officer for market integrity from Esma And then here right to my left Chiara McGonigal, who's assistant general counsel at ISDA So I should say that again we will Would like to use the Mentimeter tool for you to ask questions By the way, we have already collected a lot of questions Some are also I think relevant now for this topic and I will get back to you Later today to see what we can do with all these questions Which we don't have necessarily time to answer today or who may be a little bit too technical So I give the floor first to Alberto on the Uriba reform. Thank you. Thank you, Cornelia so I guess at the morning I had Not bad news, but it's realistic news about Ionia So I hope to bring some comfort with regards to to your I work now So this part, you know, so your I where is a major interest your interest reference rate It is administered by by EMI and this currently calculated from the contributions of a panel of 20 Banks Across Europe. So your I board was Categorized as a critical bench work by the Commission given the European Commission given its importance for financial stability and because of the wide use across a number of Financial contracts. So what you can see there is just to I guess To show you how important it is. So this is a quantitative mapping exercise that the The working group made at the very beginning of of the of the efforts and What what it shows is so taking into account the the 2020 deadline that we were discussing in the morning How much of all those Contracts by asset class would be outstanding after 2020 if the Uriba or if the reform were not to be successful therefore Your I board would not be deemed complying with the with the regulation It's only just to show you how how crucial it is that that the Uriba reform Succeeds so according to the to that quantitative mapping exercise the depth of the Uriba reference market is of about I mean About 62.6 trillion euro of your I will link financial transactions Will remain outstanding on the first of January 2020 so taken taking this into account and not only but also the recommendations of Iosco and the FSB back in 2013 Amy started the Uriba reform. So the Uriba reform Was not only It is now focused on the methodology but Amy has done a lot of a lot of work in In enhancing the transparency as well as the whole governance and control framework of the UI were benchmark Resetting process so The ultimate goal of the reform was to evolve the current quotes quote based termination methodology to a fully transaction based methodology In order to provide the market with a more transparent robust and representative index And that was the work that they made it for over three years so since the first recommendations from from from Iosco and the FSB were were published we conducted two big data collection exercises With the panel banks back then and not only the panel banks also with the support with the technical support of the ECB to assess and Develop a fully transaction based methodology That was 2013 2014 In 2016 a few months prior to the implementation of the the methodology we rerun an analysis To see whether that fully transaction based methodology would still make sense under the current market conditions and the conclusions were published on the 4th of May 2017 and Where that given the current market conditions so the liquidity in the market transition from the current current quote based methodology to one fully based on transactions is Simply not possible. It's not not robust so on the basis of of Those results those findings Amy has been working since the summer last year 2017 on the development of a hybrid methodology for your Ivor so that's a Methodology that calculates the submissions of the banks based on three different levels So it's hierarchical levels That you can see on the slide. So first you have So I mean do not forget that the regulation asks us to define a methodology that is Encored in transactions to the extent possible. So I guess that we are relying on the to the extent possible so first we have a level that is Based on transactions that satisfy certain criteria that Demi has defined and that reflect What your Ivor's underlying interest is then we have a second level that is also based on transactions but are adjusted either are adjusted to feed the your Ivor curve or Reflect or they are brought forward from previous days So level one submissions from previous days would be considered as level to input for today and then there is a Third level that relies on transactions that have not been used in any of the previous two levels as well as other market pricing sources And what the panel banks are supposed to do with all this information is to to estimate their cost of funds According to guidelines provided by me. So this is the methodology that that we developed It was developed together with a task force of market experts the FSMA so our supervisor participated as an observer in the efforts of the of the task force and The this methodology was the Was the main point of first consultation that was published at the beginning of this year The feedback that we received in response to that consultation was positive It was supportive of our our efforts and then we continued by testing this methodology With real data so under life under life conditions. So that's So before I've referred to the pre-live verification program So what we conducted this summer was the hybrid driver testing phase so it ran from May until the end of July 2018 and Three months three months no three weeks ago on the 17th of October. Amy published a second consultation paper That presents a summary of the findings from this from this testing phase and it also discusses Emmys Proposals for the different methodological parameters That had yet to be defined So the consultation period is still open. So I would encourage you to go to Emmys website. It may not be as fancy as another webpage that has been referred to previously, but you can find the document there and we would encourage really to read the consultation paper and Send your responses. So it is very important to get the feedback from the market because it is very likely It is for sure that we are going to go forward with the methodology. So it is important to get your feedback Following the analysis of the data and the submissions that were collected as part of the of the hybrid driver testing phase We are confident that the hybrid methodology is a robust evolution of the current quote based non-compliant with the BMR methodology and in turn this methodology the hybrid methodology Has a lot of potential to be compliant with the regulatory requirements of the BMR So Emmys calculations indicate that So there were a lot of rumors about the spread and the volatility and this is information that was published in the consultation So our calculations based on the data that we received Indicate that the hybrid methodology yields a rate which presents a natural market driven volatility that across all maturities ranges between 0.5 basis points and one basis point and in terms of average spreads between your I were calculated with the current quote based methodology and You ever calculated under the hybrid methodology we estimate that We estimate that across all maturities This spread ranges between minus five basis points and minus one basis point So the Belgian FSMA commended Emmy on the work done to develop and test the hybrid methodology and they indicated that it represents a Significant step towards an EU BMR compliant driver. So In the last meeting of the euro RFR working group a few weeks ago They also mentioned that you they would make an effort to expedite the authorization process once Emmy files for authorization An important prerequisite for the FSMA would be the assurance that panel banks are operationally ready and willing to contribute under the new hybrid methodology when it comes to the implementation of the Of the methodology it will be faced. So the face the implementation of the methodology will occur during 2019 and we intend to apply for authorization to the Belgian FSMA By Q2 2019. So that's well ahead of the two-year-long transitional Provision period that is contemplated under the EU BMR. So all you know It's better news than for you on our side. Thank you very much. I better, please again If you have questions, you can put them already now in the in the Mentimeter tool So we would move on and give the floor to Micaela Mazzoni from Esma on the written plans Thank you for an idea. So Good afternoon everybody Today, I'm here to talk about a single BMR requirements Which I believe affects most of you in the audience and is BMR article 28 to the content of which is in the first Slide before looking at the content. I would like to clarify a couple of things in relation to this obligation First it applied to all benchmarks. There is scope of the BMR That's for it apply also to a rival We just heard from Alberto the plan for authorization that MES developed It's important to understand that this obligation apply Before authorization after authorization in case a rival is authorized in case not authorized it apply in all cases and The second point is that and hope you're already aware of this this obligation applies its 1st January 2018 so it's been applicable in the last 11 months and In case your organization is not up to speed with this with this obligation I will urge you to to Implement and fulfill this obligation as soon as possible Now as concerned the con the content of the obligation as you can see it affects supervised entities This is a term defined in BMR so in case your supervised entity and You use a benchmark also use of a benchmark is a term defined BMR So if you tick these two definitions, what you have to do is to produce written plans that are sort of contingency plans that include your The action you will take in case the benchmark you are referring is materially change your system to be provided the obligation this requirements continue and say that We're feasible and appropriate this written plan has to include Alternative benchmarks. I think this is an important paragraph also to consider in relation to the current arrival circumstances and Then last but not least This written plan should be reflected in the contractual relationship That you have with your clients Now this is the text of the BMR article 28 to that essay this has been already applicable basically for the last 11 months At Esma what we have done is to issue a couple of Q&A's that you can find on our website You have the link at the bottom of this slide that Try to help market participants in implementing this obligation So in the first one we provide some flavor some additional details of what what a written plan can include While in the second we explain that this term that we have seen in the previous slide contractual relationship with clients is something governed by national law because Contractual law changes from member state to the member states however And I'm reading so the our guideline our Q&A provides some general principle that you should follow and In particular the fact that the supervisor entity should be able to demonstrate to the competent authority That you have communicated the written plan to the clients and That such written plans are legally affected under the applicable national law so Now the question I think is how to best Reflect this contractual relationship This written plan in the contractual relationship with clients and I think we all agree that the best way Is to include full back closes in the contracts that you have with your clients or In the financial instruments that you issue that reference a benchmark And in this respect, I want to point out a couple of things I believe that the the European the euro risk-free rate working group is considering whether it is in a position to provide some public guidance on how to include Full back closes in new contracts So in case this happen I would suggest you to check the ECB webpage dedicated to this working group because you can have Additional input and guidance on how to fulfill this requirement while in the in the derivative space and I don't want to say the presentation and is double will make in a second but Is that publish a document in September that is called the benchmark supplement Which was developed on the basis of these BMR article 28 to So as concerned the derivative space covered by is the agreements. There is already a public document Which I think is very good in in order to fulfill article 22 of the benchmark regulation So to recap you have a BMR requirement that is already applicable You have the text of the of the level one the benchmark regulation We at Esma. We issue some guidelines some Q&A's You have already needs the documents that cover these requirements potentially we have additional input from the working group and If you have Additional question on how you can fulfill this I suggest you to contact the National competent authorities of your country. You can find the list in our Esma website And I think that's all from my side Thanks very much. So I hope that was useful information for you in order to prepare for this And I understand also the working group plans to say something on this eventually So I hand over to Dominique to update us on the working group. Thank you So To start this presentation, I must tell you how happy I am today to present you as a work done by the group 22 has a since the last six months we did Tremendous amount of work and you will see the results and Thank you for that for the whole participants of the work group too so To start with our mandate, this was an important step for us. So our mandate is to explore the Fallback the possible fallback arrangements for you ribos This is this is very important because we've been talking extensively about the Uribo reform and Alberto just presented the last reform. So one of our Assumption in this working group is that the Uribo reform will be BMR compliant We have we need to have to work on this assumption. So we're working on a fallback So the job is to determine and recommend a term structure methodology for a risk-free rate Fallback for Uribo link contract. It's it's it's key. I mean each word accounts for Has counted for the work that we have done With ING we put in place what we call a high-level implementation plan and in that there were actually three missions I should say the first was the first one was to define the selection criterias for term structure methodology. So It was this has been a long process and a lot of discussions very interesting Then to assess the term structure methodologies against selection criteria. So to assess the The methodologies this has been a long technical work Because we had to imagine effectively not solution like in the subgroup 4 but Methodologies based on technical assessments. So it's been very interesting also, but very long very long work And finally which will be the last part almost the last part of our job Will be to organize a public consultation and I can tell you that this one Is not the best part for for us because we are not used to To organize a public consultation and to ask the right questions around this So we will in this consultation we will propose our select selected approach But we will also be totally transparent on the way we've been working and the other of course methodology that we've been working on and Thinking about a lot and then that we have we have a few questions and we will take into account your remarks so Second and this all this work has been done in a certain background or context As I said the first one was a Uribo reform It was very important very important for us to know exactly what will be the future of the Uribo and and to have an assumption on that So now we are We'll have more information that I should say even if there is still a Risk for Uribo not being compliant, but this is not our our job to judge this The second one is The Ionia ester transition. Why is it so important for work group 2? It is that to To have to make as a methodology working. We need to have a liquid derivative market If we don't have a liquid derivative market We cannot we can imagine all the other possible methodologies, but it will never work So this is this is key and that's why for us It is important that the transition is as quick as simple as efficient as possible and Carlos explained that very well this morning And then we have some other groups working on benchmark. We have of course the FSB Recommendation that we must take into account We have the ISDA consultation that would be exposed after After I finish so also it's important for us to coordinate closely with ISDA And also we have the work done by other jurisdictions other work groups Citing mainly the ARC and the Sonya group Actually, we are developing some relationship and some coordination with them Why is it important because we I don't know but we all do a cross-currency swaps and when you do a cross-currency swaps You have to index so we need to be current somewhere in the in them in the methodology we will choose even if For these two groups they have a different mandate and they have a different Things to sort out that I said don't really work on fallbacks, but this is another another session So Having say that I Wanted to we wanted to show you effectively What has been done as far as now so the first to work was on selective materials as I said so globally Globally you will find a lot of very precise and detailed documentation about what group to work on ECB site So this is what's not the purpose today to go deeply into details so On this slide you can see that all the criterias that have been selected Globally it corresponds to three big Iosco principle the data sufficiency the benchmark design and transparency and of benchmark Sorry determination, so this was a three main point and we've been working actively on this So once this criteria Criterias were fixed and we all agree on on these criterias We had to assess these criterias versus the different methodologies That we have working on these are the methodologies So you you will you will find the methodology that have been Also proposed by other work groups actually so the first one is the future based second one is the OIS code based Then we've been working on the OIS transaction based We we are also working but we start a bit late to work on this So it's not I don't want to present it today on the Composite methodology, which is a mixed of the OIS code based and the OIS transaction based We presented this methodology at the last Preneurization on the 18th of October. So also you can find all the details on the site of ECB But for the moment we're still working on it. It's it's it's not so it's quite complex The last the last thing is a so this this three or four with a composite the methodology are forward-looking methodology and the last part is concerning is the backward-looking methodology So backward-looking methodologies is very specific. We know that In the ISDA consultation you focus a lot on this methodology because you focus on derivative actually don't forget that we on Working on the new methodology for URI boiling contract means that you work a lot on cash products But it's really widespread. So we favor The forward-looking methodology for the moment We're still working on the backward-looking because we need to to also show some Some clues on these methodologies But globally as we think that we we need to show one methodology to choose one methodology as a fallback as a fallback This is important We we will rather favor forward-looking methodology So this is the word on this slide you can see the pro and cons I'm not going through it because don't have really Time for for that, but we are available for more details if you need we can call one of us So what is now the next steps so you can consider that job is done We work on methodology we can recommend one now We're most already, but it's not finished yet because as a matter of transparency as we said before on On the rest of the work work done by the work group. It is very important for us to share Our work to share all the assumptions we've been working on to share the methodology house or has been built with you With the market we consider already that in the work group you have a large Amount of expertise and the large part of the market which is represented But don't forget again that on on the uribo rip fallback the use the end users are Very widespread and go into the retail retail space. So it's important to communicate on this so as I as it is said As a scope is to to validate a Recommendation so we will recommend one methodology then we will ask you to validate First by the working group first my work group to then by the work group the whole work group and Then we will go public with a few questions not too much and This will help us because we will have with your feedback and this will help us to make to Maybe go on additional analysis. We just want to be sure that we didn't forget anything so To conclude We have to again to coordinate our efforts with all the Initiatives that are taken on benchmark on other jurisdictions, but also by groups like is that it is very important We have to go on having extensive discussion into the world group on term structure even if we consider that we are well advanced and We think that we have We have been studying all the actual possibilities and Then finally we will consider our job is really finished and then we can recommend a methodology When we will have the feedback from our public consultation and maybe we will have to go into further analysis Voila, thank you Thanks, Dominique So it's really a very complex task to think about the development of term rates especially with all the uncertainties that we still have and Also in conjunction with the other jurisdictions where they're looking at similar problems We can also learn from them of course, but we also see how we can coordinate so Is that is very active globally on Issues related to iBORs developing fallbacks and Transitions so I give the floor to Karen. Great. Thank you very much and thank you very much for the opportunity to present today on iBORs work across a number of different benchmark initiatives including work to improve the contractual robustness of contracts that are linked to Key iBORs such as such as your iBOR Before I begin I think anybody who's been to an ISDA conference or seminar on benchmarks has probably seen some version of this slide But I think it's useful in attempting to differentiate between the different benchmark initiatives That is they're involved in Before speaking specifically about our work on iBOR fallbacks So broadly speaking we distinguish or distinguish between I suppose three different types of initiatives So the first one is iBOR transition and then we have the iBOR fallbacks work And then we have our work on fallbacks related to article 282 of the European benchmark regulation So I think within those categories. It's probably Useful to distinguish between two broader categories. So one the voluntary transition process Which we expect to happen during the lifetime of an iBOR which is clearly the work being done by or led by The working group on euro risk-free rates in the eurozone and other public private sector groups in other jurisdictions And then the work on fallback so emergency provisions which are intended to be triggered upon the permanent discontinuation of a rate such as a key iBOR like Excuse me like your iBOR Within the category of fallbacks again to sort of categories here So on the benchmark supplement first just I suppose Following up on Micaela's presentation. We have developed a series of fallbacks Driven largely by the requirements under article 282 of the European benchmark regulation But the benchmark supplement is intended to be global in scope It doesn't just apply to those rates which might be subject to the benchmark regulation And what the benchmark supplement does is that it introduces fallbacks into derivatives as the product definitions booklets to the extent necessary so Identifying products where the existing fallbacks are either not robust or where fallbacks don't exist at all The benchmark supplement introduces a waterfall of fallbacks So so the way that works is that if there is a disruption to one of the rates that's referenced within a contract The parties will first attempt to agree upon themselves what the rate replacement rate should be if they can't do that They will look at any replacement rate that might have been nominated prior to entering into the transaction If that doesn't work, they may look to any replacement rate that might have been nominated by a regulatory authority or other body If that doesn't happen, they can move to calculation agent adjustment and failing all of those steps The parties can elect for a new fault termination Which is clearly not a great outcome But probably better than the alternative which would be the operation of an unrabust fallback Which might require parties to go out Into the market and obtain quotes or even worse scenarios where there are new fallbacks at all and you may end up with contractual frustration So separately and this will be the focus of my talk today Is this been engaged at the request of the FSB's official sector steering group? To work on fallbacks for specific key I borse so work towards improving their contractual robustness of Contracts which which reference those by incorporating Fallbacks into our 2006 is the definitions To introduce appropriate fallbacks for trades referencing those those key I borse Before I move on to that, I suppose it's it's useful to Explain a little bit around how the benchmark supplement and the I borse fallbacks Interact so the benchmark supplement has been published so to the extent that people enter into trades today Referencing the 2006 is the definitions the benchmark supplement will be incorporated into those trades the fallbacks will apply for legacy trades We're anticipating publishing a protocol at some point the next couple of months That will operate by introducing those amendments to legacy trades which reference the relevant product definitions in Respect of the I borse the benchmark supplement applies to those today So the I borse are obviously of the definitions related to the 2006 is the definitions to which the benchmark supplement applies Ultimately once the I borse fallbacks are published the idea is that will supersede the operation of the benchmark supplements You'll have a first order of fallbacks relating to the I borse fallbacks Supplement or however, that's ultimately published before then falling back to the the fallbacks contained in the benchmark supplement I appreciate that's a little bit complex. So apologies Focusing on the I borse fallbacks work specifically so in 2014 the OSSG as I think was mentioned earlier today Published their market participants group final report and that find that in most cases Fallback provisions within contracts are not sufficiently robust to cater for a permanent cessation Of a key I borse such as your I bor which acts as a reference for over a hundred and fifty trillion euros of financial products in July 2016 The OSSG invited is that to participate in its work to enhance the robustness of derivatives contracts referencing Those key I borse and as I mentioned just now is there undertaking work to amend the 2006 definitions to implement fallbacks To a range of key I borse which are on the side here, and I suppose most relevant for this group your I bor and Euro libor So how will they work? So the I borse fallbacks as I mentioned before designed to be used upon the permanent discon discontinuation of the relevant I borse So As we've been developing the fallbacks one of the things that became very clear is it was it was really important to get a consensus and agreed position as to what is meant by a permanent discontinuation And it was clear that that needed to be or operate As a predetermined and objective contractual trigger in order to avoid confusion in the market around when it when a Fallback or when a disruption or when a permanent discontinuation had actually happened As you think if certain parts of the market consider that a discontinuation has happened and others don't you may lead to market Fragmentation and for the exacerbate some of the the market disruption around the potential discontinuation of that I bor So the triggers what are they so the objective triggers that that we've come up with we've worked with our as the Relevant as the working groups to come up with these To trigger so one a public statement or publication of information By or on behalf of the administrator of the relevant I bor Announcing that it has ceased or will cease to provide the relevant I bor permanently or indefinitely And then the other trigger would be a public statement or publication of information by a public authority such as a regulatory supervisor An insolvency official or a central bank Which states that the administrator has ceased or will cease to provide the relevant I bor again permanently or indefinitely? Important to note that in both scenarios that presumes that there will be no successor administrator that will continue to provide the relevant I bor so we're talking about a scenario where The I bor has permanently discontinued and there's no replacement administrator That's willing to take over the administrative function with respect to that rate Also important to note that the fallbacks themselves won't actually kick in until the actual discontinuation of the rates So if you consider a scenario where there's an announcement that an I bor may be discontinued at some point in the future The I bor fallbacks wouldn't be designed to kick in until that rate is actually discontinued again in order to avoid market confusion So the fallbacks Themselves will be the fallbacks to the relevant risk-free rates that have been selected in each jurisdiction So in the euro area that would obviously be Esther But clearly there's some work to do there the RFRs are overnight rates Whereas the I bor's have term structures and incorporate bank credit spreads and risk premium So for that reason in order for the fallbacks to work effectively in order to mitigate mitigate against the risk of value transfer and further market disruption It'll be necessary for us to incorporate a term and spread adjustment to those RFRs When triggering the fallbacks so that they can work as smoothly as possible So in terms of how the contracts themselves will be amended as I've said previously as there will amend the 2006 is the definitions, which is where the definitions relating to those I bor's are currently contained the amendment will The amendment to the definitions will Incorporate those objective predetermined triggers that I mentioned earlier And it will also incorporate the fallbacks that will apply with respect to each rate each I bor upon the occurrence of that trigger so the fallback again being to the relevant RFR as adjusted to account for any term and spread adjustment As with the benchmark supplements As I mentioned at the beginning important to note that once the amendment to the 2006 is the definitions Has been published they will only apply in respect of new transactions going forward So it will be necessary for is that to publish a protocol which will have the effect of amending existing transactions referencing those rates To incorporate and to ensure that those I bor fallbacks are in place So how will we determine I suppose those term and spread adjustments as Dominique mentioned is to have Published a consultation on 12th of July of this year We launched a market consultation of both is the and non is the members in order to determine the methodology that should be used in Calculating the appropriate spread and term adjustment for each of the I bor's That consultation closed last month on the 22nd of October and is that is currently analyzing the results The responses to determine what approach that we should take in each instance So we intend to publish a full explanation of how we made our determination We expect to do so by the end of the year. Although that's not set in stone We will before doing anything we will publish the final approach for review. We will publish Information around how we made the determination as to which which of the various methodologies Should apply we will do that as I said before we actually go about making any adjustments or amendments to the relevant documentation So for this audience, I think it's it's important to note that the consultation although it asked some preliminary questions around your I bor It didn't specifically cover that rate because as you see July 12th When the mark when the consultation was published the identity of the euro risk-free rate wasn't yet known So now we know that it's Esther and we anticipate that next year once Esther is published that we'll launch a supplemental consultation covering your I bor And we will conduct out in the same way as we have done so so that's something to to look for next year And I think that's everything for me Thanks very much Karen So may I remind you one final time that now we will have questions and answers or if you want to put a question You can still put it on Mentimeter Yeah, and to allow for some time for that maybe a short wrap up of the of the session So this time positive news from from Albedo and as a working group We are extremely happy with that because it would be of a massive task of we also have to replace your I bor So thanks for the hard work and hopefully it will indeed be a full success So we expect somewhere half first half and the first half maybe third quarter your positive news And that's good because Mikael already made clear that despite your I bor probably surviving We still need to have a plan if it's easy to exist So we need to have plans in place as of all the contracts we have closed as of the first of 2018 Sometimes there are some confusions about that But that is the case and also for legacy contracts contract before 2018. We have to do this on a best effort basis We have to be ready for a potential transition massive task Not so easy to perform also since we don't have these fallback yet in place So it's it would really help and when when we have done our work So we fully realize that but already making the inventories is very important Luckily Dominique with the working group is doing a lot of work on creating that fallback. So that is our reaction to Getting also these full backs in place Looking at the outside world very important looking at the regulations looking at the FNF Sb but also with the the the worldwide RFR working groups like the RR dark the arc like the Sonya working group But also the Swiss the Japanese we have now contacts with all these working groups Work is progressing. So we have already identified the selection criteria very important and also we identified the various alternatives Not so easy also since we don't have a working derivative market yet So we have to do the work all under the assumption that the derivative market will be there once we start publishing Esther And the consultation will also go out on this one. So watch out for that one And then of course very important to Karen talking about the is that in the fallback language A very good example. So a lot of work have been done on is that also Yeah, it's it's for derivatives But of course for us, it's also very important that we have fallback language that is consistent across our products Because that would mean that in the end we don't end up with a basis risk. So the work on is that site? Yeah, for me, it's very important to also Set it should be a sort of template for fallback language that we have on other products So that we at least can fall back to the same benchmark. So a lot of work there Very important that it will be based on the new RFRs like Esther. So that is also very positive But still yeah, we need spats. We need spats for term and credit spread risk or also complicated task there I think the main conclusion also of the day is there is a lot of work also for you guys because I think there will be three to four consultation papers heading your way so it will be a busy Christmas time and first quarter of the year So we hope to get a lot of feedback from you because we fully realize that we can think about nice solutions But if the market and that is you does not accept our solutions. Yeah, we don't make stand any chance So thanks for your reaction already now Thanks, yeah, so Philip could you tell give us a few questions that you have collected The participants have been very active. So a first question is I sense a lot of interest in the preparation of Emmy for the phasing in of their methodology Maybe you could elaborate a bit more on that point Also, what how you would cater for the spread in that trend in order to ensure a smooth transition So as I said, so Amy's planning to conduct this phased transition from from the current methodology to the To the new methodology starting in in 2019 So we are in close contact with so again, I mean this is all being done in close collaboration or discussion with the FMA At this point, I mean the information that is public Is basically what I just said. So we're still trying to refine the details of that of that facing that facing is in previous also So first we need to guarantee that the banks are operationally ready So the phasing will allow for that and also In order to minimize any impact. We are trying to avoid a big bang implementation As if I mean it was planned to to be done in the case of the pre-life Well, the you ever plus the fully transaction based so Again, so we are planning to to conduct the phasing over 2019 apply for authorization by Q 2 2019 and have the hybrid methodology fully implemented by the end of Q 3 2019 Second question relates is probably more for Dominique. It's the question how long You estimate that it would take to develop a Term structure based on as there and what would be the role of the Transition or the relevance of the the union as that transition and in their process. What how could you get all these? as the implementation phase will probably take Just say the few months this is part of the work we still have to do to see I don't know to look for an administrator to work with a with a platform suppliers, etc. So It's very difficult for the moment. We have a timeline in term of The world group but then for the moment. It's very difficult to assess How long it will take which is certain is that The quicker as I said now the quicker is a transition the quicker is Esther can have We can have a liquid derivative market on based on Esther the better it is if at the end of the year we have a Liquid derivative market on on Esther. It means that the fallback could be could be computed We have the methodology so we just need the underlying So that's that's the answer I can I can make it's very difficult to say take one two three months one year to your It's really it all depends on the On the Esther at the derivative market And probably also on the transition part that we will choose because then yeah If it will see if you only able sees to exist or not or be fully linked to Esther We will force the liquidity probably in the in the OS market towards as the derivative. So that would make a The conclusion of a derivative market quicker if it would run in parallel. Yeah, you could still have a dispersed market So we're looking at those alternatives and we have a lot of questions on on the numerous consultations that are announced so I think there are two two questions what these will be used for whether they will have be used also By regulators in enforcing one a change in one direction or the other and There's a call for a bit more coordination in in these Consultation process so is I think that's one of the question is can the number be reduced Yeah, I think it's a good question The problem is that our timelines are still very tight And this problem is massive So yeah, we have to take the market by the hand in showing in full transparency the work that we do Which means that we need to also Consultate make the consultations on the various topics Yeah, that forces a little bit that we have a multiple Consultations coming out in the beginning of the year So apologies for that and we fully realize it But I still think it's very important that we that we reach out to the market because you have to know where we are What our thinking lines are? It also helps you in your preparations So it will be very difficult to do not do these consultations or only do these One after the other because then we will run out of time With the first of gen 2020 is there quite quickly And probably just another point I would mention I think although a lot of these consultations I think look superficially similar some of them are driving at slightly different things. So Some of them are looking at transitions. Some are looking at fallback. So I think it's Important as opposed to understand what the consultation is actually trying to achieve and the objectives behind it as well Then there's also a question on whether the development actually of fallbacks Might not lead to an outcome where those markets become more active and are detrimental than to to the new Euribus, right? So whether market partisans Have done a preference to move directly to those those fallbacks rather than Stay with Europe Can be And just over now, we are very very happy that the Euribus is still Will likely or hopefully be BMR compliant if we see more activity in our fallback solution and that can very well happen because also Internationally, we see the developments that they are more pushing towards Terms of success based on this free rates Yeah, that can also be a development that we see on euros at the end in a euro landscape And I think we would be perfectly happy with that So I think it would not be necessarily be bad. I mean, I think that the spirit of the FSB the recommendations were not only It was not so much about It was about having alternatives So I think that right now there may be an even over reliance on your Ivor and that's why we are here So that's why there is a systemic risk So I mean having an alternative and starting using other other benchmarks at least I mean, I don't think that it is necessarily a problem There's also a question on who will be the administrator of the new term rates and How that was that as a process for determining this how that will be led that procedure The work group has not yet decided exactly what will be the procedure for that we have administrators in our work group Very well represented, but for the moment We have not really envisaged that question That's it We have time for like two more questions or are you basically I Think I cover most as some as some Questions that do not relate to our our home turf so the euro era. So why would like those need to be addressed to other Entities and there was a more practical question whether the material would be made available that we show here And I think we can say yes. Yes All the slides presentations will be available on our website Thanks, Philip Okay, then I'd like to thank the panelists very much