Although July 3 was the first business day on which no USD LIBOR was published, many financial instruments will not reset until the next reset date, based upon the tenor of each instruments’ underlying benchmark, which could...more
Back in March of 2021, we covered a number of developments pertaining to the end of LIBOR that came out of certain announcements made early that month by the Intercontinental Exchange Benchmark Administration (the “IBA”),...more
As market participants prepare to submit comments on the recent proposal of the UK’s Financial Conduct Authority (the “FCA”) (available here) to require the temporary publication of a “synthetic” 1-, 3- and 6-month USD LIBOR,...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
On March 15, 2022, the Consolidated Appropriations Act, 2022 – which included the Adjustable Interest Rate (LIBOR) Act – was signed into law. The LIBOR Act is meant to address concerns with ceasing the use of LIBOR by...more
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
In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more
The Internal Revenue Service and the US Treasury Department have issued final regulations providing rules for taxpayers transitioning from interbank offered rates to qualified rates. These regulations provide financial...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
EU SSR: ESMA proposes permanently lowering reporting threshold of net short positions - The European Securities and Markets Authority (ESMA) has published an opinion in which it recommends that the European Commission...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
The end of March has welcomed Spring, and this year it marks a new era for the financial markets, particularly for loans and financial products which would usually use Sterling LIBOR as the benchmark for calculation of...more
On 5 March 2021, the Financial Conduct Authority ("FCA") announced (the "FCA Announcement") the future cessation or loss of representativeness for all 35 LIBOR settings currently published by ICE Benchmark Administration...more
Recent statements by LIBOR authorities in the UK have implications for benchmark fallbacks in US documents. The UK’s Financial Conduct Authority ("FCA") and ICE Benchmark Administration ("IBA") released statements1 on...more
This bulletin provides a timely update on two emerging issues related to LIBOR transition – namely, requirements that administrative agents (including private credit lenders acting in that role on their facilities) may be...more
Publication of U.S. dollar (USD) LIBOR rates used in many financial instruments may continue longer than expected. On November 30, 2020, ICE Benchmark Administration (IBA), the administrator of LIBOR, released a statement...more
The staffs of the Securities and Exchange Commission’s Division of Corporation Finance, Division of Investment Management (IM Division), Division of Trading and Markets, and Office of Chief Accountant (collectively, Staff) on...more