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Financial Benchmarks

Representative Engagements

Financial benchmarks play vital roles for pricing and risk allocation in markets globally. Public confidence in benchmarks is critical to the efficient functioning of the financial system and the global economy. The financial industry and regulators are developing comprehensive reform measures to ensure that benchmarks are well-designed and appropriately controlled. Promontory has emerged as the leading consultancy in this field, assisting clients to implement new benchmark design and control standards and providing thought leadership for regulation and reform measures.


Financial benchmarks are intrinsic to the smooth functioning of every major financial market across all asset classes. Benchmarks are also essential in the execution of public monetary and economic policy, helping to transmit policy objectives through trillions of dollars of market activity. Current regulatory and market initiatives are likely to result in new targeted regulation and enhanced requirements for benchmark sponsors and data contributors in governance, operating controls, and benchmark design.

Several broad reform principles have already emerged. Many jurisdictions will regulate benchmark activities, including sponsorship and data contribution, which will require strong governance and tight and auditable controls on benchmark determination and data submission. Benchmarks may be redesigned to more accurately reflect underlying markets and make increased use of data from actual transactions. These reforms are vital to maintain public confidence in benchmarks, but present implementation and cost challenges to benchmark sponsors and market participants.

With its teams of industry leaders and regulatory experts, Promontory is uniquely positioned to assist clients in implementing reform requirements, including benchmark design, independent assurance, gap analyses against emerging standards, and look-back investigations. Promontory has advised several benchmark sponsors, data contributors, and industry associations on a variety of benchmark issues, including policy development, operational assurance, and investigative reviews. The firm has a unique operational facility dedicated to benchmark-review activities, using sophisticated technology to support investigative and assurance programs.

Representative Engagements

Benchmark Sponsors

  • Promontory assisted the sponsor of one of the most widely used global interest rate benchmarks to undertake comprehensive enhancements to its governance and control framework. The project included the development of an extensive code of conduct for benchmark activities, as well as guidance on internal governance and controls at data contributors.
  • A global benchmark sponsor engaged Promontory to assess its current systems and controls, and compare them to anticipated regulatory requirements for governance, risk management, compliance, independence, and investor protection.
  • Promontory reviewed the methodology, governance structure, and controls implemented by two benchmark sponsors in the interest rate and commodities markets. Promontory developed recommendations for enhancing and documenting the sponsors’ control environments, and assisted with their implementation.
  • Promontory assisted a major, globally active, calculation agent to strengthen its control framework for major benchmarks, including the development of a code of conduct.

Data Contributors

  • Promontory performed a preliminary investigative review for a panel-member bank of one of the major rate indices, and was subsequently engaged to perform a full forensic review covering multiple years of prior activities. Promontory employed its dedicated operational facility for this in-depth review.
  • On behalf of a global bank acting as a panel member on a major rate index, Promontory reviewed an investigation of data contributions conducted by internal and third-party resources. Promontory reviewed the institution's plan to enhance its controls for benchmark-setting activities, and advised on the reporting of the investigative work and the systems and controls enhancements to the financial institution’s supervisor.

Industry Associations

  • Promontory assisted a global trade association to develop best practices for global benchmark indices. Promontory’s work also included the promotion of the standards among the associations’ members, extensive regulatory and market outreach, and comment-letter responses to regulatory consultations. The best-practice standards were referenced positively in a number of the major regulatory reviews of benchmarks. Promontory also assisted the association in responding to global and regional benchmark developments.

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