Bloomberg L.P. 731 Lexington Ave Tel +1 212 318 2000 New York, NY 10022 bloomberg.com 15 July 2016 Ms. Sandra O'Connor Chair Alternative Reference Rates Committee Federal Reserve Bank of New York 33 Liberty Street, New York, NY 10045
[email protected] Via email Dear Ms. O'Connor: Bloomberg, L.P. ("BLP") appreciates the opportunity to provide input on the Alternative Reference Rates Committee's ("ARRC") consultation request regarding its Interim Report and Consultation ("Report").1 BLP commends your work as Chair of the ARRC and the work of the ARRC as a whole. BLP, the global business and financial information and news leader, gives influential decision makers a critical edge by connecting them to a dynamic network of information, people and ideas. The company’s strength – delivering data, news and analytics through innovative technology, quickly and accurately – is at the core of the Bloomberg Professional service, which provides real time financial information to more than 325,000 subscribers globally. BLP is focused on giving our customers the financial tools they need to navigate the markets and develop and execute their financial and business strategies. BLP has a strong interest in having a benchmark that is well-governed, highly resistant to manipulation, and properly calibrated to lending risks. BLP offers the following responses to the consultation: 1) The ARRC has narrowed its focus to two potential alternative rates, the Overnight Bank Funding Rate ("OBFR") and an overnight Treasury general collateral repo rate. Do you have a preference between these two rates? If so, why? The OBFR has advantages in that it is based on a robust pool of market transactions, including both overnight fed funds and Eurodollar transactions.