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
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
The London Interbank Offered Rate's (Libor) regulator, the Financial Conduct Authority, and administrator, Intercontinental Exchange Benchmark Administration (ICE), on March 5, 2021, announced that the publication of 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 past Monday, July 26, marked passage of the most recent major milestone in the replacement of LIBOR as the benchmark USD interest rate. Following the recommendation of the CFTC’s Market Risk Advisory Committee (MRAC)...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
The State of New York has enacted a new law that should ease the transition away from US dollar LIBOR for legacy financial contracts that are governed by New York law but do not contain modern benchmark fallback provisions. ...more
March was a big month for the LIBOR endgame. There were several big announcements, some important (but technical) developments, and new deadlines. Simply put, the March developments matter to the fund finance community...more
The upcoming transition from LIBOR, which is published by ICE Benchmark Administration Limited (IBA), to the Secured Overnight Funds Rate (SOFR), which is published by the New York Federal Reserve Bank (NYFRB), has prompted a...more
The London Interbank Offered Rate (“LIBOR”) is a benchmark interest rate index used in setting the interest rate for many variable-rate loans and other financial obligations. LIBOR is currently set to be phased out in...more
Following the ARRC-recommended deadline for shifting to hardwired fallbacks, the syndicated loan market has begun to show signs of change - Based on best practices published by the Alternative Reference Rates Committee...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
The Financial Conduct Authority (“FCA”), the UK regulator of LIBOR, announced several years ago that it would no longer compel panel banks to provide LIBOR quotes after December 31, 2021. The FCA also stated in March of this...more
Often referred to as “the world’s most important number”, the London Interbank Offered Rate (LIBOR) is used as the reference interest rate for a range of commercial and financial contracts worth hundreds of trillions of...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