Construction Webinar Series: Construction Contractors: Considerations in Subcontracting Plans and OFCCP Compliance
Carrie Penman on Helpline Data Since the Pandemic
Podcast: CFTC Issues LIBOR Transition Relief for Swaps
The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not...more
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
As we kick off 2024, the focus on the unavailability of certain benchmarks continues on. To refresh, we have already seen the benchmark for US Dollars generally replaced with the Secured Overnight Financing rate as...more
Summary - After pausing last month in its ongoing series of rate increases, the Federal Reserve Board today bumped up its benchmark interest rate, the fed funds rate, by .25% to a range of 5.25% to 5.50%—a 22-year high....more
As we finish the last season of LIBOR replacement, the fund finance market is busy amending our loan documents to include SOFR as the interest rate benchmark for U.S. dollar loans. While the cessation date for USD LIBOR is...more
On November 23, the UK’s Financial Conduct Authority (“FCA”) released its further consultation to require the administrator of LIBOR to publish a synthetic version of 1-, 3-, and 6-month U.S. dollar LIBOR settings for a...more
On July 19, the Federal Reserve issued a notice of proposed rulemaking (“NPR”) that would implement the Federal LIBOR Act. The NPR focuses primarily on identifying the particular version of SOFR that will apply to legacy...more
Hitting the year-end deadlines was hard. Your kind words eased that pain like a week’s vacation on a remote island with no wifi. I have saved every single one of those emails, texts and LinkedIn messages and filed them away...more
The State of New York has enacted a new law that should ease the transition away from US dollar LIBOR for legacy financial contracts that are governed by New York law but do not contain modern benchmark fallback provisions. ...more
On April 7, 2021, the proposed New York “legislative solution” for legacy USD LIBOR contracts became Article 18-C of the New York General Obligations Law. Article 18-C is primarily aimed at USD LIBOR contracts, securities or...more
March was a big month for the LIBOR endgame. There were several big announcements, some important (but technical) developments, and new deadlines. Simply put, the March developments matter to the fund finance community...more
Operational resilience: developments in the financial services sector in the UK - In recent years, operational resilience has come under the spotlight of financial regulators globally, leading to a proliferation of new...more
In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more
The London Interbank Offered Rate (LIBOR) expires at the end of 2021. Used since the early 1980s, LIBOR is the most referenced global short-term interest rate, and a “standard benchmark”....more
In July 2017, Andrew Bailey, chief executive of the UK Financial Conduct Authority (FCA), announced that by the end of 2021, the FCA would no longer seek to compel or persuade panel banks to submit quotes for LIBOR....more
The reference rate provided by selected panel banks to the LIBOR administrator, ICE Benchmark Administration (IBA) and that is used to establish interest rates on many loans, notes, bonds and other financings, derivatives,...more
SIFMA hosted a briefing on July 15 at which presenters from the NY Fed, FCA, ARRC, Wells Fargo, Freddie Mac, Fannie Mae and SIFMA discussed the progress that has been made thus far in preparing for the transition from LIBOR...more
I attended the recent ARRC roundtable discussion on the LIBOR to SOFR transition and was struck by the tenor of urgency in the discussion – urgency to begin operational preparations for the transition; urgency to inventory...more
On second thought, Wall Street does have some questions about the specifics of the pause in the trade war that apparently emerged from the G-20 sidelines this weekend. And when Wall Street has questions—well, not a banner...more
Since the loss of liquidity in the inter-bank market following the global financial crisis and more recently the emergence of LIBOR-manipulation concerns, regulators have announced plans for reforming benchmark rates. Given...more
U.S. Financial Industry Developments - LIBOR "Transition" - While there is a way to go until the end of 2021 when panel banks will no longer be required to provide LIBOR quotes to the FCA, we expect to see more and more...more
Agencies Propose Simplifying Regulatory Capital Rules - On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed...more
The Mortgage Credit Directive (2014/17/EU) (MCD) requires that creditors create two illustrative examples for variable rate mortgages on the basis of a benchmark rate specified by the EBA. Consequently, the EBA has developed...more