In its response to the Commission’s consultation on a framework for regulating benchmarks, ESRB has focused on macro-prudential aspects of this reform. It cautions that, in the transition to a new regime, a binding conversion could threaten continuity of contract and result in litigation. It also suggests that financial markets would be better served by more diverse benchmarks that take into account structural changes in bank funding and are a closer measure of risk-free interest rates. This diversity would also prevent volatility being transmitted across markets. Reliable benchmarks must also have rules for conceivable eventualities and periods of market stress. (Source: Macro-Prudential Aspects of the Reform of Benchmark Indices)