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FCA announcement triggers LIBOR endgame

On 5 March 2021, the UK Financial Conduct Authority (FCA) and the administrator of LIBOR, ICE Benchmark Administration (IBA) each made important announcements for parties to instruments or other contracts referencing LIBOR. ...more

IBA announces consultation on extension of LIBOR transition deadline to end of June 2023

On November 30, 2020, Intercontinental Exchange, Inc. (ICE) announced that the ICE Benchmark Administration Limited (IBA), a wholly-owned subsidiary of ICE and the administrator of LIBOR, will consult in early December 2020...more

LIBOR transition gets a jumpstart: ISDA announces ISDA IBOR fallbacks provisions and related protocol

As we have previously reported, in July 2017, the UK Financial Conduct Authority announced that it would no longer use its legal powers to persuade or compel contributing banks to make the transaction data submissions...more

ISDA publishes benchmarks supplement

On September 19, 2018, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA Benchmarks Supplement, which allows adhering entities to amend the contractual triggers and fallbacks of...more

December 31, 2021, changes to the London Interbank Offered Rate (LIBOR) are coming—will you be ready? 

Dramatic changes are on the horizon for the most widely used benchmarks for interest, investment and derivatives rates: the London Interbank Offered Rate (LIBOR) for various currencies. Notwithstanding efforts by regulators...more

The Deadline for Compliance With the U.S. Variation Margin Rules Is Approaching! Are You Ready?

The requirement that non-cleared swaps be fully margined, which is one of the last pillars of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), will take effect for “financial end-users”...more

ISDA Publishes EMIR Classification Letter

On July 13, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA EMIR Classification Letter (the Classification Letter), a form of letter that may be used by market participants managing their...more

ISDA Section 2(a)(iii) Amendment Limits Prerogatives of Non-Defaulting Parties

On June 19, the International Swaps and Derivatives Association (ISDA) published a long-awaited standard amendment to Section 2(a)(iii) of the ISDA Master Agreement (the Master Agreement). Section 2(a)(iii) of the Master...more

Update: An End-User’s Guide to the CFTC’s Final Cross-Border Guidance

There were a number of new developments with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requirements for swaps in the latter part of 2013. This...more

Legal Alert: ISDA Accepting Comments on Draft Dodd-Frank "Protocol 2.0"

Pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act (Dodd-Frank), the Commodity Futures Trading Commission (CFTC) has adopted a number of final regulations that require swap dealers (SDs)...more

CFTC Extends Compliance Dates for Dodd-Frank Requirements Necessitating Amendments to Existing Trade Documentation

On December 18, the Commodity Futures Trading Commission (CFTC), by private vote, adopted interim final rules (Interim Final Rules) to amend the compliance dates for previously issued final rules that establish external...more

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