On September 28, 2012, HM Treasury published the final report on the review of the London Interbank Offered Rate (LIBOR) undertaken by Martin Wheatley, Financial Services Authority (FSA) Managing Director and Chief-Executive designate of the Financial Conduct Authority (FCA) (the “Wheatley Review”). The Wheatley Review followed the two-volume report published in August 2012 by the House of Commons Treasury Select Committee after it became apparent that Barclays Bank had manipulated its submitted rates.

The Wheatley Review detailed key conclusions and recommendations, as well as a ten-point plan for broad LIBOR reform. Of particular interest, the Wheatley Review sets forth the following...

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