The Administrator announces that a consultation on proposed changes to the methodology for the below benchmarks has begun
The Administrator proposes changes relating to the below sections of the Methodology only
Consultation Process
The consultation for all aspects of this proposed change and its proposed date of implementation is now open and will close at 1630 LDN on June 4rd, 2021. All responses will be treated in confidence unless a respondent specifies that it wishes its identity to be known to the Administrator.
Submission of Responses
Please submit responses to [email protected]. When submitting your responses please give as much detail as possible and please be specific with any suggestions or concerns.
Proposed Date of Implementation
The Administrator proposes to implement the proposed changes to the Settlement Prices from June 28th 2021 onwards
Rationale
The applications of the CF Settlement Prices in financial products have increased significantly over the past 6 months and are likely to continue to do so. The Administrator proposes these changes to ensure both the integrity of the benchmark and that any potential market disruption it could cause is sufficiently mitigated.
Likely Impacts
The proposed methodology changes mean that product providers that replicate or utilise the Settlement Prices may need to alter the provisions for extraordinary events in their product mechanics and market participants may need to factor these changes into their processes when transacting in instruments that are linked to the Settlement Prices
Further to general comments the Administrator will seek to understand from index users what the likely impacts could be in vis a vis:
Timeframe of Proposed Change
Whether the proposed change allows market participants to make the necessary arrangements to potentially alter product mechanics and provisions around extraordinary events
Financial Impact of Proposed Change
The financial value of contracts, instruments, funds that directly reference or are settled according to the benchmark that shall be impacted by the proposed change.
Market Impact of Proposed Change
The number of counterparties and types of counterparties that could be adversely impacted and the scale of the disruption they would face as a result of the proposed change.
The revised sections of the proposed methodology are shown below.
Delayed data and missing data are treated according to the following rules:
All Relevant Transactions retrieved by the Calculation Agent for a given Calculation Day are subject to an automated screening for erroneous data according to the following rules:
Relevant Transactions flagged as erroneous for a given Calculation Day are disregarded in the calculation of the CF Settlement Price for that Calculation Day.
If all Relevant Transactions of all Constituent Exchanges are flagged as erroneous for a given Calculation Day, a CF Settlement Price calculation failure occurs for that Calculation Day (see Section 5.5).
All Relevant Transactions retrieved by the Calculation Agent for a given Calculation Day are subject to an automated screening for potentially erroneous data according to the following rules:
Relevant Transactions flagged as potentially erroneous for a given Calculation Day are disregarded in the calculation of the CF Settlement Price for that Calculation Day.
If all Relevant Transactions of all Constituent Exchanges are flagged as potentially erroneous for a given Calculation Day, a CF Settlement Price calculation failure occurs for that Calculation Day (see Section 5.5).
Where for any reason the Administrator is not able to calculate and publish a CF Cryptocurrency Settlement Prices within the Dissemination Time on any given Calculation Day then the Administrator shall publish a notification on its website at blog.cfbenchmarks.com informing index users that calculation and publication has been delayed. The Administrator will seek to publish the CF Cryptocurrency Settlement Price for that Calculation Day as soon as it is able to. Should the Administrator not be able to calculate and publish a CF Cryptocurrency Settlement Price by 23:59:59 London time then the provisions of Rule 5.6 shall come into effect.
The Administrator does not utilise expert judgment in the day to day calculation of the Settlement Prices. In extraordinary circumstances Expert Judgement may be exercised by the Administrator in accordance with its codified policies and processes which are available upon request.
If a CF Settlement Price cannot be calculated for a given Calculation Day before 23:59:59 London time, for instance because:
Then the CF Settlement Price for that Calculation Day is given by the CF Cryptocurrency Settlement Price on the previous Calculation Day and this Settlement Price shall be published with a marker of (*)
The occurrence of any CF Cryptocurrency Settlement Price calculation failure is reported to the CF Oversight Function and announced at blog,cfbenchmarks.com.
Th CF Cryptocurrency Settlement Prices are subject to restatement and republishing before 23:59:59 London time of any given Calculation Day due to errors made by the Calculation Agent or its systems. CF Cryptocurrency Settlement Prices will not be subject to republishing after this time.
The Administrator shall only Restate and Republish CF Cryptocurrency Settlement Price value if both the below conditions are met:
Example:
OR
Where the above conditions are met the Administrator shall announce on its website that a restatement and republishing of the CF Cryptocurrency Settlement Price will take place for that Calculation Day.
The Administrator shall restate the impacted CF Cryptocurrency Settlement Price as soon as possible and shall do so by overwriting the previously published CF Cryptocurrency Settlement Price. This restated CF Cryptocurrency Settlement Price will carry no mark when published and will be final and not subject to any further change or republication.
Where a Market Failure Event has occurred, this shall be announced by the Administrator on its website. The CF Cryptocurrency Settlement Price on a day where a Market Failure Event has occurred shall be given by the CF Cryptocurrency Settlement Price published for the previous Calculation Day. Any CF Cryptocurrency Settlement Price published on a day when a Market Failure Event has occurred shall be marked by a maker (*).
Should the consultation result in the Administrator not implementing any of the proposed changes or the implementation date being changed then this and any further shall be announced by the Administrator. Any queries regarding the consultation process should be addressed to [email protected].
The information contained within is for educational and informational purposes ONLY. It is not intended nor should it be considered an invitation or inducement to buy or sell any of the underlying instruments cited including but not limited to cryptoassets, financial instruments or any instruments that reference any index provided by CF Benchmarks Ltd. This communication is not intended to persuade or incite you to buy or sell security or securities noted within. Any commentary provided is the opinion of the author and should not be considered a personalised recommendation. Please contact your financial adviser or professional before making an investment decision.
Note: Some of the underlying instruments cited within this material may be restricted to certain customer categories in certain jurisdictions.
Ken Odeluga