Construction Webinar Series: Construction Contractors: Considerations in Subcontracting Plans and OFCCP Compliance
Carrie Penman on Helpline Data Since the Pandemic
Podcast: CFTC Issues LIBOR Transition Relief for Swaps
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
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
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
HM Treasury has published a policy paper and draft legislation for extending the transitional period for third-country benchmarks under the U.K. Benchmarks Regulation. The transitional period will be extended from the end of...more
Summary - After pausing last month in its ongoing series of rate increases, the Federal Reserve Board today bumped up its benchmark interest rate, the fed funds rate, by .25% to a range of 5.25% to 5.50%—a 22-year high....more
On 13 June the European Commission (the Commission) published a new package of measures to bolster the EU sustainable finance framework. Its aim is to: “ensure that the EU sustainable finance framework continues to...more
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
Last month, the Financial Conduct Authority (FCA) announced that, after conducting a “preliminary review” of ESG benchmarks, “the overall quality of ESG-related disclosures made by benchmark administrators was poor” and...more
The Federal Reserve has adopted a final rule that provides benchmark replacement rates based on SOFR (Secured Overnight Financing Rate) for contracts governed by U.S. law that reference the overnight and one-, three-, six-,...more
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
On September 8, the UK’s Financial Conduct Authority (“FCA”) published a “Dear CEO” letter setting out its strategy and supervisory priorities for overseeing benchmark administrators under the UK Benchmark Regulations (“UK...more
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
Hitting the year-end deadlines was hard. Your kind words eased that pain like a week’s vacation on a remote island with no wifi. I have saved every single one of those emails, texts and LinkedIn messages and filed them away...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
The Basel Committee on Banking Supervision (“BCBS”) published a report jointly with the World Bank setting out the findings from a global survey on proportionality in banking regulation and supervision....more
While the end of widespread use of the U.S. Dollar London Inter-Bank Offered Rate (“LIBOR”)1 has been looming for several years, there have been a number of key developments recently in the transition away from LIBOR that...more
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
Following the end of the Brexit transition period, debt capital markets participants may now need to consider both EU rules and the parallel UK rules for EU and UK transactions, particularly those that are cross-border. ...more
Operational resilience: developments in the financial services sector in the UK - In recent years, operational resilience has come under the spotlight of financial regulators globally, leading to a proliferation of new...more
Homestretch to December 31, 2021, and the end of LIBOR? Not so fast. All the relevant regulators and other authorities clearly indicated for some time that USD LIBOR would no longer be available after December 31, 2021,...more
In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...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 October 21, 2020, the UK Government introduced the Financial Services Bill (the Bill) to Parliament. The Bill is seen as a vital step towards ensuring the UK’s continued status as a global finance hub in the post-Brexit...more
In September and October 2020, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) is administering its next mandatory Benchmark Survey of Financial Services Transactions between U.S. Financial Services...more
Overview - The BE-180 report issued by the U.S. Commerce Department’s Bureau of Economic Analysis (the “BEA”) is a five-year benchmark survey that collects data on transactions between U.S. financial services providers...more