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Sub Committees

There are two sub-committees of the LIBOR Panel Banks and Users Group: 

1 Fixings Sub-committee; and

2 Oversight Sub-committee

These will be chaired by the Deputy Chairs of the LPBAUG.  Membership will be taken from the members of the LPBAUG.

Fixings Sub-Committee 

This sub-committee scrutinises the rate setting process and meets as requested by the BBA LIBOR Secretariat or the LPBAUG. Should an issue arise that has not been resolved by Thomson Reuters, it is referred to the BBA LIBOR Secretariat who initiates an investigation and reports in full to the LPBAUG, who may then refer the matter on to the Fixings subcommittee. The outcome of the deliberations and any recommendations of the Fixings sub-committee are then passed on to the Oversight Committee for final decision or reported to the LPBAUG.

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

Oversight Sub-Committee

Should the Fixings subcommittee decide that an issue warrants sanction against a contributor bank, the query will then be referred on to the Oversight subcommittee. The sanctions that can be applied by the subcommittee include:

Written guidance. On the instructions of the Oversight sub-committee the BBA LIBOR Secretariat 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 LPBAUG.

If a contributor receives guidance, the Oversight 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 is either considered to be resolved 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.

Recommendation for next review The Oversight sub-committee may issue a recommendation to the LPBAUG that a contributor is removed.  This will happen either when it is considered that the contributor has not complied with written guidance, or if the Oversight sub-committee believes the bank is unquestionably in breach of the bbalibor definition or terms of reference for contributors.  The Oversight subcommittee 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. 

 
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