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Holland & Knight LLP

CFPB Issues Final Libor Transition Rules

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The Consumer Financial Protection Bureau (the Bureau) has issued final regulations (Final Regulations) to facilitate the transition away from Libor (the London Interbank Offered Rate) in the consumer credit market and to...more

ArentFox Schiff

Federal Law to the Rescue?

ArentFox Schiff on

Snidely Whiplash kidnaps Nell and, in the show’s opening, ties her to the railroad tracks to get even with his nemesis, Dudley Do-Right, of the famed Royal Canadian Mounted Police. Menacing music plays. In each episode,...more

Holland & Knight LLP

Libor Discontinuation: Update for Floating Rate Borrowers

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This alert provides a brief summary of a recent development that may impact borrowers that hedge floating rate debt. ...more

Holland & Knight LLP

Libor Administrator Proposes Extending Timeline for Discontinuing Some U.S. Dollar Benchmarks

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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

Eversheds Sutherland (US) LLP

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

King & Spalding

What Happened to My Interest Rate? A Deep Dive into Hardwiring Predictability and Fairness for LIBOR Transition in Loans,...

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The U.S. dollar LIBOR interest rate index is the most widely used variable interest rate benchmark in the world, serving as the reference rate for over an estimated $200 trillion of financial products worldwide, and official...more

Goodwin

OCC Finalizes “True Lender” Rule

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In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Dechert LLP

Quick Note: The NY Fed is Publishing Compounded SOFR Screen Rates

Dechert LLP on

The Federal Reserve Bank of New York announced last week that it will be publishing “Average SOFR” for 30, 60 and 90 days on its website starting on March 2, 2020. The confusing thing about this announcement is that the Fed...more

ArentFox Schiff

The End of Libor

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For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more

Holland & Knight LLP

Treasury Department, IRS Issue Proposed Rules on Tax Impact of Transition from Libor

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The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more

ArentFox Schiff

The End of Libor – Proposed Helpful Guidance for Borrowers from the Treasury Department for Tax Exempt Bond Obligors – With Some...

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Many conduit tax exempt revenue bonds bear interest at a floating rate, most typically a percent of USD 1-month LIBOR (here, LIBOR). Many of these transactions have been synthetically “fixed” by the conduit borrower entering...more

Holland & Knight LLP

Summary of ARRC's Libor Fallback Proposal for Floating Rate Notes

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• The Alternative Reference Rates Committee (ARRC) recently released proposed fallback language for Libor-based floating rate note (FRN) transactions in anticipation of the cessation of Libor in 2021. • The board of...more

Orrick, Herrington & Sutcliffe LLP

An End User’s Practical Guide to the QFC Stay Rules

The Board of Governors of the Federal Reserve System (Board), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) adopted rules (together, the QFC Stay Rules) in 2017...more

Foley & Lardner LLP

The Phasing Out of LIBOR: Initial Reaction and Preparation

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1. Background: Elimination of LIBOR by 2021 - As has been widely publicized, on July 27, 2017, the U.K. Financial Conduct Authority announced that LIBOR (London Interbank Offered Rate) the longtime global interest rate...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 7, Issue 7

Financing Subsidiaries and SEC Registration - As readers of this publication know, in order to address the expected new U.S. regulatory capital requirements, a number of U.S. bank holding companies have been creating new...more

Morrison & Foerster LLP

The Federal Reserve’s Proposed Rules for Financial Contracts of Global Systemically Important Banking Organizations and ISDA’s...

Last month the Board of Governors of the Federal Reserve System (the “Board”) issued proposed new rules (the “Proposed Rules”) intended to reduce the potential risks posed to the U.S. financial system by too-big-to-fail...more

A&O Shearman

US Federal Reserve Board Proposes Rule on Close-Out of Qualified Financial Contracts Involving Large, Complex Financial Firms

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The US Federal Reserve Board proposed a rule to support US financial stability by enhancing the resolvability of large, complex financial firms. The proposed rule would require US global systemically important banking...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

EBA Outlines Upcoming Initiatives for the Regulation of Retail Payments - The European Banking Authority ("EBA") has announced details of its plans to harmonize regulatory and supervisory practices to ensure secure, easy...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Lawmakers and Regulators Continue Focus on Strategies for Resolving SIFIs"

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more

Morrison & Foerster LLP

Federal Reserve Board and OCC Issue Interim Final Rule Amending U.S. Bank Capital and Other Rules to Account for Global...

On December 16, 2014, the Office of the Comptroller of the Currency (“OCC”) and the Board of Governors of the Federal Reserve System (“Board”) (collectively, “Agencies”) issued an interim final rule (“IFR”) amending the...more

Dechert LLP

Orderly Unwinding: Here to Stay?

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The International Swaps and Derivatives Association (ISDA) recently issued the ISDA 2014 Resolution Stay Protocol (Protocol), which takes effect on 1 January 2015. The Protocol aims to prevent adhering parties from...more

Orrick - Finance 20/20

Federal Reserve Board and FDIC Welcome ISDA Announcement

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On October 11, the Board of Governors of the Federal Reserve System and the FDIC applauded the International Swaps and Derivatives Association (ISDA) for the agreement of a new resolution stay protocol....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

ESMA Securities and Markets Stakeholder Group Responds to ESMA Consultations on Draft Technical Standards and Technical Advice on the Market Abuse Regulation - On October 13, the Securities and Markets Stakeholder...more

Goodwin

Financial Services Weekly News Roundup - October 2014 #3

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Editor’s Note - Looking Ahead: December 1 Effective Date for FINRA Consolidated Supervision Rules. The new FINRA Supervision rules, approved by the SEC in December 2013, become effective on December 1, 2014. The new...more

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