The consultation considered whether re-fixing should be applied if any errors in LIBOR be discovered later in the day, beyond the immediate period for checking that occurs prior to publishing the rates each morning. The proposal would allow LIBOR to be re-fixed at 4.00pm and this would replace the 11.00am rate. The ACT has very strongly opposed this explaining that it is hugely disruptive to re-write history when actions will already have been taken based on the 11.00am rate. Far better to leave the 11.00am rate as the official fix and publish any correction in the afternoon as a memorandum.
The consultation also envisages truncating LIBOR to three (from five) decimal places. Given upward rounding practices, this increases bias and so we recommend retaining the five places.