ESMA_QA_854

Status: ✅ Answer Published

Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/854


Regulatory Context

Regulation : BMR

Level 1 Regulation: Benchmarks Regulation (BMR) - Regulation 2016/1011

Level 2 Regulation: No information available

Level 3 Regulation: No information available

Topic: Benchmarks Regulation

Subject Matter: Readily available data


Question

Submission Date: 26 June 2022

What does “readily available” data according to Article 3(1)(8) of the BMR mean? What is the difference with the other types of input data such as regulated data?


ESMA Answer

Answer Date: 23-06-2022

Answer provided by the European Commission in accordance with article 16b(5) of the ESMA Regulation Input data is defined in Article 3(1)(14) BMR as the data in respect of the value of one or more underlying assets, or prices, including estimated prices, quotes, committed quotes or other values, used by an administrator to determine a benchmark. The concept of readily available data is not defined in the BMR. The BMR states only that the data is either contributed to the administrator for the purposes of determining a benchmark or it is readily available. Whether input data is contributed or is readily available has no bearing on the administrator’s responsibility as defined in Title II of the BMR. At the same time, the BMR accepts that it cannot impose rules (e.g., code of conduct by a benchmark administrator) on data sources that simply publish data which are later used to piece together a benchmark. The summary table below sets out the consequences of this categorisation of input data. Summary table

Types of input data

Readily available data

Contribution of input data

 

Regulated data

Non regulated data

Not provided to an administrator for the purpose of determination of a benchmark

Provided to an administrator for the purpose of determination of a benchmark  

Provided to an administrator for the purpose of determination of a benchmark

 

 

Contributed entirely and directly from the entities listed in Article 3(1)(24)  

 

Exemptions applicable to the benchmark

Readily available data

Regulated data

Non regulated data

Article 11(1)(d) and (e), (2) (a) and (b) and (3) - Input data   Article 15 – code of conduct for contributors   Article 16 – governance and control requirements for supervised contributors

Article 8(1)(a) –record keeping of all input data   Article 11(1)(d) and (e), (2) (a) and (b) and (3) - Input data   Article 14(1) and (2) – integrity of input data, and detection and reporting of manipulation or attempted manipulation   Article 15 – code of conduct for contributors   Article 16 – governance and control requirements for supervised contributors

None - other exemptions may apply depending on the type of the benchmark (interest rate, commodity, significant or non-significant)

Examples

Transaction data made publicly available (for example by a DRSP)   MMSR data provided to the ECB which is used to calculate €STR   Data collected and published by a central bank or other public authority as part of normal regulatory data-gathering   Transaction data sourced from a non-EU trading platform with no equivalence decision, not provided to an administrator for the purpose of determination of the benchmark

Transaction data sourced directly from an EU trading platform or data service provider   Transaction data provided by a TV on a real time basis

Input data contributed to commodity benchmark administrators or an administrator of an interest rate benchmark   Transaction data sourced from a non-EU trading platform with no equivalence decision, provided to an administrator for the purpose of determination of the benchmark

  Disclaimer: The answer clarifies provisions already contained in the applicable legislation. It does not extend in any way the rights and obligations deriving from such legislation nor does it introduce any additional requirements for the concerned operators and competent authorities. The answer is merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.


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