The Federal Reserve Board issued a final rule last week that establishes default rules for benchmark replacements in certain contracts that use the London Interbank Offered Rate (LIBOR) as a reference rate. LIBOR will be...more
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
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
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
In our October 2019 alert, we advised that LIBOR (London Interbank Offered Rate) will not be available for use as an interest rate index after December 31, 2021 (the LIBOR Cessation). As the end of 2021 approaches, here is...more
This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more
On July 26, 2021, Neal R. Pandozzi participated as a presenter in the Strafford CLE webinar "The Phase-out of LIBOR: Navigating the Final Stages, Implementing Alternative Reference Rates and Fallback Language." The webinar...more
Wednesday, the ARRC announced (HERE) the expectation to endorse CME’s Term SOFR in late July or early August. One of the bigger pieces to this announcement is the announcement that U.S. regulators will also permit Term SOFR...more
On April 6, 2021, New York Governor Andrew Cuomo signed into law the New York State Legislature’s Senate Bill 297B/Assembly Bill 164B (the New York LIBOR Legislation), strengthening the groundwork for the forthcoming...more
On March 24, 2021, New York State’s Senate and Assembly approved LIBOR transition legislation. New York Governor Andrew Cuomo’s consent awaits and is expected as the governor indicated his support earlier this year...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
Recent developments mean a delayed departure for LIBOR. The cessation of most U.S. dollar LIBOR tenors has been delayed until June 30, 2023. Aircraft financiers, borrowers and lessors should take advantage of the...more
This alert provides a brief summary of a recent development that may impact borrowers that hedge floating rate debt. ...more
On November 30, 2020, the ICE Benchmark Administration Limited (IBA), the administrator of the London Interbank Offered Rate (LIBOR), announced that it would consult on its plan to cease the publication of one-week and...more
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
On November 6, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued an inter-agency...more
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
The Board of Governors of the Federal Reserve System and the Federal Reserve Bank of New York convened the Alternative Reference Rates Committee (ARRC) in 2014 to develop an alternative rate and conversion methodology for the...more
In the News. The Securities and Exchange Commission (SEC) proposed modifying the disclosure framework for mutual funds and exchange-traded funds (funds), which would create a new layered disclosure regime that attempts to...more
In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more
On April 8, 2020, the Alternative Reference Rate Committee (“ARRC”) agreed to align itself with the International Swaps and Derivatives Association, Inc. (“ISDA”), in recommending to the market a “spread adjustment”...more
On March 6, 2020, the Alternative Rate Reference Committee (ARRC), the Federal Reserve’s LIBOR-transition working group comprised of private-sector entities and industry regulators, released its New York State legislative...more
On March 6, 2020, the Alternative Reference Rates Committee (ARRC) convened by the Federal Reserve Board and the Federal Reserve Bank of New York released a proposal for New York State legislation that is intended to reduce...more
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
The New York Federal Reserve Bank's Alternative Reference Rates Committee (ARRC) released its recommendations on Nov. 15, 2019, regarding the London Interbank Offered Rate Index (Libor Index) fallback language for new...more