ICE Benchmark Administration Ltd (IBA) has published an update following feedback to its position paper regarding its proposals for the evolution of LIBOR. A recurring theme in the feedback was that benchmark submitters should transmit eligible transaction data to IBA, rather than submissions, and that IBA should calculate LIBOR rates from the transactional data. This was seen as likely to result in a reduced need for subjectivity. IBA stated that it was important to recognise that in the absence of sufficient transactions, some form of expert judgement will still need to be exercised and the capacity of IBA to provide this will have to be carefully considered. IBA intends to publish a further paper in early 2016.