Sub Committees

There are three sub-committees of the FX&MM Committee: 

1 Fixings Sub-committee;

2 Oversight Sub-committee; and 

3 LIBOR Steering Group.

These will be chaired by the Deputy Chairs of the main committee.  Membership will be taken from the members of the FX&MM Committee.

Fixings Sub-Committee 

This sub-committee scrutinises the rate setting process and meets as requested by the bbalibor manager or the FX & MM Committee. Should an issue arise that has not been resolved by Thomson Reuters, it is referred to the bbalibor manager who initiates an investigation and reports in full to the Fixings sub-committee. The outcome of the deliberations and any recommendations of the Fixings sub-committee are referred to the FX&MM Committee for final decision.

Issues raised from sources other than Thomson Reuters will be investigated by the bbalibor manager and the same reporting structure will be followed.  The Fixings subcommittee may instruct the LIBOR manager to visit contributor banks to discuss their quoting behaviour in confidence and provide a written report of this.

Oversight Sub-Committee

Should the FX & MM Committee decide that an issue has not been satisfactorily resolved in conjunction with the contributor then action will be initiated via the Oversight sub-committee. Tools at their disposal are detailed below, and will include but are not limited to: issuing written guidance, to include a re-statement of contributor protocols; requiring an up-to-date audit of a panel bank’s contribution processes; other measures as appropriate or in extremis, a recommendation that a contributor be removed from the relevant panel at the next review. In the latter case this must be approved by a special meeting of the FX & MM Committee.

Discipline of contributors may take three forms:

Written guidance. On the instructions of the Oversight sub-committee the FX & MM Committee secretary will write to the contributor in confidence detailing the reasons the contributor is believed not to be acting in accordance with the bbalibor definition or terms of reference for contributors and ask them to justify or remedy their actions.  A full record of all correspondence will be kept and presented to the next meeting of the FX & MM Committee, however this will not be made public

If a contributor receives guidance, the sub-committee will set a date to re-convene and review the actions of the contributor since the original guidance was issued.  At this point the issue will either be closed or disciplinary action will escalate.

Requirement for a Re-Audit. The Oversight sub-committee may issue a recommendation that a contributor is required to re-audit their internal rate submitting processes. This could happen when it is considered that the contributor is not reliably complying with the written guidance or if there are concerns with the existing audit process.

Recommendation for next review The Oversight sub-committee may issue a recommendation that a contributor is removed at the following review of bbalibor contributors.  This will happen either when it is considered that the contributor has not complied with written guidance, or if the group believes the bank is unquestionably in breach of the bbalibor definition or terms of reference for contributors.  The group may ask for external input from legal counsel to ensure that decisions do not raise competition law issues or implicitly favour one bank over another.  In either case the secretary will retain records which will be made available to observers and the BBA auditors. 

bbalibor Steering Group

The LIBOR Steering Group currently meets bi-annually with the sole purpose of considering the LIBOR Review and providing a recommendation to the FX & MM Committee. bbalibor Steering Group members will be FX & MM Committee members who are active market participants, who therefore will have knowledge of current market decisions and able to make recommendations to the FX & MM Committee.