The Financial Markets Law Committee (FMLC) has published its response to the Bank of England's second consultation paper on the reform of the SONIA interest rate benchmark, which was published in October 2016. Points of interest include the following: (i) the FMLC refers to the Financial Stability Board's report on reforming major interest rate benchmarks, which was published in July 2014; (ii) the FMLC agrees with the BoE's approach on legal risk and financial contracts; (iii) the FMLC considers market standard terms in relation to contractual definitions and next day publication and how these might accommodate benchmark evolution; and (iv) the FMLC supports the way in which the consultation paper aligns the analysis of SONIA with the benchmark concepts now widely adopted in international regulation.