On May, 27, the Alternate Reference Rate Committee (ARRC) that works under the auspices of the Federal Reserve Bank of New York issued a set of “Best Practices for Completing Transition Away from LIBOR.” The Best Practices reinforce the ARRC’s position that markets should cease using the London Inter-bank Offered Rate (LIBOR) as a reference rate in financial transactions well before the December 31, 2021 end date identified by UK regulators by providing specific dates by which specific products should be LIBOR-free.
Continue Reading LIBOR Transition Best Practices Statement Issued by ARRC

The International Swaps and Derivatives Association, Inc. (ISDA) has launched a new webpage containing information about interest rate benchmark reform and the transition away from the use of interbank offered rates (IBORs, including LIBOR) as floating rates in swap transactions. The page and subsequent materials are available to everyone, not just ISDA members.
Continue Reading ISDA Launches Benchmark Reform Information Source

On May 13, the UK’s Financial Conduct Authority (FCA) and the UK’s Prudential Regulation Authority (PRA) announced that they will resume full supervisory engagement with dual regulated firms on their London Interbank Offered Rate (LIBOR) transition progress from June 1, 2020 (the Announcement). Such engagement will include data reporting at the end of Q2 in light of the PRA and FCA suspended transition data reporting at the end of Q1 for dual regulated firms and the Banks of England’s (BoE) Financial Stability Report on May 7, 2020 regarding the impact of COVID-19 pandemic.
Continue Reading BOE, FCA and PRA Update on LIBOR

On February 27, the UK’s Financial Conduct Authority (FCA) published a “Dear CEO” letter regarding the London Interbank Offered Rate (LIBOR) (the Letter). In the Letter, Head of Asset Management Supervision at the FCA, Nick Miller, noted that “LIBOR will cease after December 2021” and that asset managers must “prepare now for the end of LIBOR.”
Continue Reading FCA Publishes LIBOR Dear CEO Letter

On January 20, the Financial Conduct Authority (FCA) published a letter to the CEOs of asset management firms to outline their view of the key risks of harm to the customers or markets in which they operate (the Letter). The FCA defines asset management firms as firms that predominately manage mainstream investment vehicles, excluding wealth managers and financial advisers.
Continue Reading FCA Publishes Dear CEO Letter for UK Asset Management Firms

On December 18, the Division of Swap Dealer and Intermediary Oversight (DSIO), the Division of Market Oversight (DMO) and the Division of Clearing and Risk (DCR) each issued a no-action letter providing relief to market participants in preparation for the transition away from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (collectively with LIBOR, IBORs). The letters identify the terms and conditions pursuant to which counterparties may be eligible for relief in connection with amending swaps to replace provisions referencing discontinued IBORs with alternative benchmarks.
Continue Reading CFTC Grants Market Participants LIBOR-Transition Relief

On December 2, the Commodity Futures Trading Commission’s (CFTC) Market Risk Advisory Committee (MRAC) announced that it will hold a public meeting at the CFTC headquarters in Washington, DC on December 11 at 9:30 a.m. Eastern. At the meeting, MRAC will receive status reports from its Climate-Related Market Risk, Central Counterparty Risk and Governance, Market

On September 9, the Market Risk Advisory Committee of the Commodity Futures Trading Commission (CFTC) approved some “plain” English disclosures concerning the risks of executing new derivative transactions involving interbank offered rates (IBORs) that will be replaced by new benchmark rates in the relatively near future. The disclosures, which are not mandatory, are intended as “helpful examples” of the information that market participants should share, as appropriate, with all clients and counterparties with whom they continue to transact derivatives referencing London Interbank Offered Rate (LIBOR) and other IBORs. They are drafted for use on a transaction-by-transaction basis, but alternatively can be delivered as part of general risk disclosures. The disclosures will be submitted to the CFTC for consideration.
Continue Reading CFTC Market Risk Advisory Committee Approves Plain English IBOR Risk Disclosures