The last publication of USD LIBOR on the basis of panel bank submissions occurred on June 30, 2023. As of July 3, 2023, 1-, 3- and 6-month USD LIBOR settings will be calculated using a synthetic methodology based on CME Term...more
On April 21, the Alternative Reference Rates Committee (ARRC) announced the endorsement of the CME Group’s Term SOFR rates, which ARRC formally recommended in 2021...more
Last year, the United Kingdom Financial Conduct Authority (UK FCA) announced the following: - ‘Zombie’ USD LIBOR for proposed use from July 1, 2023, through September 30, 2024, except for cleared derivatives - 1-Month and...more
In May 2022 we reported that where Term SOFR was being used widely in U.S. loans; its use in other markets was more limited. Six months on, how has the picture changed?...more
The U.S. dollar London Interbank Offered Rate (Libor) publication is scheduled to end by June 30, 2023. With roughly nine months to go as of this writing, parties still have time to make modifications to existing debt...more
Summary - The Alternative Reference Rate Committee (ARRC), convened by the Federal Reserve Board and the New York Fed to help ensure a successful transition from LIBOR to SOFR, this week published its LIBOR Legacy...more
Term SOFR, the forward-looking term rate based on the Secured Overnight Financing Rate (SOFR), has become an established benchmark rate for new US Dollar lending in the US syndicated loan market....more
On March 5, 2021, the Financial Conduct Authority (FCA) announced the future cessation or loss of representativeness of the 35 LIBOR benchmark settings currently published by ICE Benchmark Administration (IBA), the authorized...more
FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more
The Great Index Reformation is coming. (I note in passing that the last Reformation led to the 100 Years War…just saying.) This is a massive change to our market that did not bubble up from the great unwashed on the...more
On July 29th, 2021, the Alternative Reference Rate Committee (“ARRC”) formally recommended the adoption of CME Group’s forward-looking Secured Overnight Financing Rate term rates (“Term SOFR”). This announcement completes the...more
On July 29, the Alternative Reference Rates Committee (ARRC) formally recommended the use of the CME Group’s forward-looking Secured Overnight Financing Rate (SOFR) term rates (Term SOFR) as a replacement to the London...more
As expected, on July 28, 2021, the Alternative Reference Rates Committee (ARRC) formally recommended the CME’s SOFR Term Rate. The SOFR Term Rate is known in advance of the related interest period and provides an indicative,...more
Following much anticipation, the Alternative Reference Rate Committee (ARRC) has announced its official recommendation of the CME Group’s forward-looking Secured Overnight Financing Rate (SOFR) term rates (SOFR Term Rates)....more
On July 29, 2021, the Alternative Reference Rates Committee (ARRC) of the Federal Reserve formally announced and recommended CME Group’s forward-looking Term Secured Overnight Financing Rate (Term SOFR) rates, marking the...more
It’s a rule around here that I don’t write on the same topic twice in a row because if you don’t get bored, I will. I am making an exception this week to revisit last week’s blog about the industry’s failure to take on, or...more
To my gentler readers, first an apology for this interregnum in publication. I’ve been sitting on this commentary like a hen on an egg for weeks. All I can say is having to work for a living gets in the way of writing about...more
The last few months have seen the pace of change accelerate in the business loan market’s transition away from LIBOR. Several alternatives to the replacement benchmark rate recommended by the Alternative Reference Rates...more
This article aims to highlight certain key differences between LIBOR, SOFR and several of the most common credit sensitive rates that are available or are in development today. ...more
In our first client alert about LIBOR’s passing, “LIBOR”s Long Good-Bye” (the First Alert), we suggested that borrowers of U.S. Dollars prepare themselves for the end of the London Interbank Offered-Rate (USD LIBOR), by...more
God knows I’m as sick of LIBOR transition as you are and writing about it twice in quick succession is annoying, but I think necessary. Here’s the headline which I don’t think has gotten the visibility it deserves: ...more
We’ve written before about our anxiety regarding the fact that SOFR does not really seem fit for purpose to support commercial mortgage lending or indeed any cash product. (The nonsense about charging interest in arrears...more
Ready or not, borrowers are involuntarily seeing changes in the interest rates they are being charged. Why, you ask? Because there are serious, systemic risks associated with the most widely used interest rate basis in the...more
On March 25, 2021, the Alternative Reference Rates Committee (ARRC) released supplemental recommendations for its hardwired fallback language for US dollar denominated syndicated and bilateral loans. The ARRC’s supplemental...more
In this Issue. The federal bank regulatory agencies announced that the temporary change to the supplementary leverage ratio for depository institutions will expire as scheduled on March 31, 2021; the Small Business...more