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SIFMA contended that "full disclosure and transparency by benchmark sponsors" is the key to a more robust understanding of existing benchmarks. SIFMA's feedback was a response to an MSRB request for feedback from market participants on the accessibility, methodology and utility of indices, yield curves and benchmarks available in the municipal market. SIFMA explained that members currently use a variety of indexes and yield curves, and that the benchmarks are used for: new issue pricing; institutional investor bids and offers in the secondary market; individual investor bids and offers in the

ISDA summarized preliminary responses to a July 2018 consultation related to new benchmark fallbacks for derivative contracts that cite various interbank offered rates ("IBORs"). As previously covered, the consultation set forth alternatives for adjusted risk-free rates ("RFRs") and spread adjustments that would apply in the event an IBOR is permanently discontinued. ISDA received 152 responses to the consultation, representing a wide cross-section of market participants. According to ISDA: the "overwhelming majority" of respondents preferred the "compounded setting in arrears rate" for the

ISDA, the Global Financial Markets Association, FIA and the Emerging Markets Traders Association (collectively, the "Associations") requested that the European Union ("EU") extend the transition period for critical and non-critical benchmarks under EU Regulation for at least two years. The Associations' statement follows a request by the Working Group on Euro Risk-Free Rates to extend the transition period for critical benchmarks. The Associations claim that the prohibition on the use of a benchmark will have a substantial impact similar to that of the cessation of a widely used interbank