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
Following the end of the Brexit transition period, debt capital markets participants may now need to consider both EU rules and the parallel UK rules for EU and UK transactions, particularly those that are cross-border. ...more
On February 13, 2021, the European Union’s (EU) amendments to the Benchmarks Regulation (2016/1011) (the Amended BMR) came into force, which provides a legislative fix for the cessation of LIBOR in legacy contracts. The...more
While a welcome development for parties to derivatives transactions generally, the launch of ISDA’s robust benchmark fallbacks may not be the most appropriate solution for IBOR cessation in finance-linked hedging transactions...more
Three delegated acts that supplement the EU Benchmarks Regulation will come into force on 23 December 2020. The long-awaited delegated acts (Delegated Acts) required by Regulation (EU) 2019/2089 (the Low Carbon Benchmarks...more
The Intercontinental Exchange (ICE) Benchmark Administration (IBA), which is the administrator of the London Interbank Offered Rate (Libor), announced on Nov. 30, 2020, that it will consult in early December on its intention...more
UK BMR: FCA approach to orderly wind down of LIBOR and consultation on Statements of Policy - The UK Financial Conduct Authority has published a document on the Benchmarks Regulation (UK BMR) and proposed amendments under...more
The European Commission has last week published a draft regulation to amend the Benchmark Regulation (“BMR”), in respect of (i) the exemption of certain third country foreign exchange benchmarks and (ii) the designation of...more
On 27 July 2017, the chief executive of the Financial Conduct Authority, Andrew Bailey, announced that the London Interbank Offered Rate (LIBOR) may not continue to be available after 2021. Since this announcement, a number...more
Tomorrow heralds an important milestone in the evolving saga of LIBOR's discontinuation, seeing the launch of the fifth and final rate, €STR, as the proposed successor to euro LIBOR. However, although in our other articles...more
In the 2018 edition of this publication, we ended the introduction with the line, “We can only hope that we will enter 2019 with greater certainty than 2018 as to how the regulatory landscape will look.” Unfortunately,...more
The Situation: The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the preliminary results of its market consultation concerning the fallbacks rates to be relied on upon cessation of certain...more
The Financial Stability Board has published a progress report on ongoing reforms to major interest rate benchmarks. The FSB has been co-ordinating international reform work, through its Official Sector Steering Group, since...more
Six months have now passed since publication of the Dechert OnPoint, LIBOR – Where Are We Now?, and in that period progress on benchmark reform and the development of alternative risk-free-rates (RFRs) has gathered pace. At a...more
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
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
U.S. Financial Industry Developments - ISDA, AFME, ICMA, SIFMA and SIFMA AMG Publish Global Benchmark Report - The International Swaps and Derivatives Association (ISDA), the Association of Financial Markets in Europe...more
Discussion of LIBOR was catapulted back into the spotlight last summer when Andrew Bailey, Chief Executive of the UK’s Financial Conduct Authority (FCA), gave a speech1 on the reference rate’s future. The key take-away was...more
In 2017, Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo made clear he will strive to improve, not abolish, many reforms the CFTC adopted to implement the Dodd-Frank Act’s mandate for new...more
In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more
Plans to end the long reign of the London Interbank Offered Rate (LIBOR) as one of the world's most often-used interest rate benchmarks have recently been confirmed by several top financial regulators. On July 27, 2017,...more
Background - The integrity of benchmarks used in financial transactions has been the subject of increasing focus from regulators since the investigations into manipulation of the setting of LIBOR, EURIBOR and other...more
On March 31, the European Parliament’s Committee on Economic and Monetary Affairs (ECON) adopted its report on benchmarks. Key issues include: The Economic and Monetary Affairs Committee backed a draft EU law to make the...more
On 18 September 2013, the European Commission (the Commission) published a draft proposal for a regulation on indices used as benchmarks in financial instruments and financial contracts (the Regulation). The Regulation will...more
On June 6, the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) published their final report setting out principles for benchmark-setting processes in the EU (ESMA/2013/659)....more
Background - As we have previously reported, a Task Force of the International Organization of Securities Commissions (“IOSCO”) published a consultation on financial benchmarks on 11 January 2013 in response, in part,...more