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Benchmarks Financial Regulatory Reform

GeoDataVision

New CRA Retail Lending Test Benchmarks

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The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not...more

Cadwalader, Wickersham & Taft LLP

Benchmarks Beyond January 2024 - 2024 Update on the Cessation of CDOR and SIBOR

As we kick off 2024, the focus on the unavailability of certain benchmarks continues on. To refresh, we have already seen the benchmark for US Dollars generally replaced with the Secured Overnight Financing rate as...more

Cadwalader, Wickersham & Taft LLP

What Are the Alternatives? April 2023 - Current State of Play of Alternative Currency Benchmark Rates

As we finish the last season of LIBOR replacement, the fund finance market is busy amending our loan documents to include SOFR as the interest rate benchmark for U.S. dollar loans. While the cessation date for USD LIBOR is...more

Cadwalader, Wickersham & Taft LLP

In Depth: 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

Cadwalader, Wickersham & Taft LLP

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

Cadwalader, Wickersham & Taft LLP

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

Cadwalader, Wickersham & Taft LLP

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

Morgan Lewis

President Biden Signs Federal LIBOR Transition Legislation into Law

Morgan Lewis on

President Biden on March 15 signed into law the Adjustable Interest Rate (LIBOR) Act, which aims to reduce uncertainty regarding the effect of ending LIBOR on existing USD LIBOR transactions, as part of an omnibus spending...more

Orrick, Herrington & Sutcliffe LLP

Tough Legacy Made Easy: An Overview of the Federal LIBOR Legislation

On March 15, President Biden signed, as part of a larger appropriations act, legislation known as the “Adjustable Interest Rate (LIBOR) Act,” which addresses “tough legacy” contracts that do not provide for the use of clearly...more

Goulston & Storrs PC

New York State LIBOR Transition Bill Signed into Law

Goulston & Storrs PC on

On April 6, 2021, New York Governor Andrew Cuomo signed into law Senate Bill S297B/Assembly Bill 164B (the “New York Legislation”), which paves the way for a smoother transition from US Dollar LIBOR and, in particular,...more

Kramer Levin Naftalis & Frankel LLP

LIBOR Benchmark Administrator to Cease Publication of One-Week and Two-Month U.S. Dollar LIBOR on Dec. 31, 2021, and the Remaining...

On Nov. 30, 2020, Intercontinental Exchange, Inc. announced that ICE Benchmark Administration Limited (IBA) is proposing the cessation of the publication of  the one-week and two-month U.S. dollar LIBOR on Dec. 31, 2021, and...more

Jones Day

Major Steps Forward for EU Sustainable Finance

Jones Day on

The Situation: Three major pillars of the EU action plan on sustainable finance ("EU Action Plan") at varying stages of development have taken steps forward. The Result: We now have a regulation on climate-related benchmarks...more

Holland & Knight LLP

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

Holland & Knight LLP on

• 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

Shumaker, Loop & Kendrick, LLP

Client Alert: What to do about the Libor Time Bomb? ARRC Adopts Recommended Fall-Back Language for Libor Based Credit Facilities

As has been widely published in the financial services sector, the Financial Conduct Authority in the United Kingdom (FCA) has determined that banks will no longer be compelled to support the London Interbank Offered Rate...more

Dechert LLP

LIBOR, Again (Sorry!)

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We are all going to be heartedly sick of discussing LIBOR and LIBOR transition long before it becomes a thing at the end of 2021, but we really need to get this done. I can’t make this at all funny. We have a problem…but not...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

Some reaction to the HQ2 x2 news, including what a pair of new tech hubs actually means for the cities that have thrown out the red carpet to Amazon and other technology giants....more

Sullivan & Worcester

Après LIBOR: Black Swan or Y2K

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A practical guide to the cessation of LIBOR and the transition to a new replacement benchmark rate. Unquestionably, the London Inter-Bank Offered Rate ("LIBOR") is an integral part of nearly every type of financial product...more

Dechert LLP

New European Commission proposals aimed at promoting growth and investment in Europe

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The European Commission has proposed a series of reforms to strengthen and further centralise supervision of the European capital and financial markets at the EU level with the aim of creating stronger and more integrated...more

Orrick - Finance 20/20

Council of EU Presidency Compromise Proposal on Benchmark Regulation

Orrick - Finance 20/20 on

On September 10, the Presidency of the Council of the EU published its first compromise proposal (dated September 9, 2014) relating to the European Commission’s proposed Regulation on indices used as benchmarks in financial...more

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