More than a year ago the world fell victim to a global pandemic that would change life in ways that could never have been predicted. In the early stages of the pandemic, we published a White Paper directed at financial...more
ICE Benchmark Administration Limited ("IBA") upends market expectations by announcing a consultation on an 18-month extension for most tenors of USD LIBOR.
IBA announced on November 30, 2020, that it would launch a market...more
The Situation: On the same day that the ICE Benchmark Administration ("IBA") launched a consultation on its intention to cease publishing euro, sterling, Swiss franc, and yen LIBOR at year-end 2021, the UK Financial Conduct...more
The proposed powers for the Financial Conduct Authority ("FCA") to manage the London Interbank Offered Rate ("LIBOR") transition should address so-called "tough legacy" contracts involving UK participants but could also have...more
On August 5, 2020, FINRA published Regulatory Notice 20-26, summarizing the results of a survey FINRA conducted of a representative cross-section of member firms, including firms with significant trading volumes or positions...more
The United Kingdom and European Union look to give powers to regulators, rather than using direct legislation, to deal with existing contracts that prove unable to convert or be amended to include fallbacks ahead of IBOR...more
The Situation: The SEC's Office of Compliance Inspections and Examinations ("OCIE") intends to examine registrants to assess preparation for the expected discontinuation of LIBOR and the transition to alternative reference...more
The Development: The Alternative Reference Rates Committee ("ARRC") announced the results of its market consultation on the "spread adjustment" calculation for the LIBOR/SOFR transition on May 6, 2020, but found it necessary...more
The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the results of its "Final Parameters" Consultation (the "Consultation") on a number of important mechanical details and specifications for...more
The Situation: The International Swaps and Derivatives Association ("ISDA") is in the midst of consulting the market on a wide variety of issues to develop "triggers" and "fallbacks" related to LIBOR cessation. Thus far,...more
The Situation: The Staffs of the Divisions of Corporation Finance, Investment Management and Trading and Markets ("Divisions") of the U.S. Securities and Exchange Commission ("SEC") and its Office of the Chief Accountant...more
7/19/2019
/ Banking Sector ,
Broker-Dealer ,
Corporate Counsel ,
Disclosure Requirements ,
Investment ,
Investment Adviser ,
ISDA ,
Joint Statements ,
Libor ,
Market Participants ,
New Guidance ,
Registration Statement ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Working Groups
The Situation: SFIG's LIBOR Task Force has released the first of a planned series of "green papers" on benchmark transition in the US securitization market.
The Result: The Green Paper contains proposed recommendations...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