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Regulatory and Transactional Implications of Recent Moody’s Bank Ratings Downgrades

Earlier this week, Moody’s Investor Services downgraded the credit ratings of 10 regional banks and put 17 other banks under review or gave their rating a negative outlook. Notwithstanding the downgrades, most of the...more

Happy FFFourth! June 2023 - A LIBOR Commencement Speech

The London Interbank Offered Rate (LIBOR) will stop being published on the basis of panel bank quotes and will be replaced by alternative replacement rates after today. In the spirit of the season, below is the commencement...more

Considerations for Counterparties Whose Swaps Are Transferred from First Republic to J.P. Morgan

On May 1, 2023, the Federal Deposit Insurance Corporation (“FDIC”) seized control of First Republic Bank (“First Republic”) and then, as receiver of First Republic, entered into a purchase and assumption agreement (“P&A”)...more

Federal Reserve Issues Final Rule Implementing LIBOR Act

On December 16, 2022, the Board of Governors of the Federal Reserve System (the “Board”) adopted a final rule (the “Final Rule”) to implement the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”).  The Final Rule follows...more

FCA Seeks Feedback on ‘Synthetic’ USD LIBOR

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

Federal Reserve Issues Proposed Rules under LIBOR Act

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

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