News & Analysis as of

Libor Financial Institutions Benchmarks

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

WilmerHale

LIBOR Fallback to Prime May Increase Corporate Loan Costs

WilmerHale on

The London Interbank Offered Rate (LIBOR) officially ceased to be published on June 30, 2023. The change comes after almost 40 years of LIBOR serving as the principal benchmark rate for trillions of dollars of various...more

Shearman & Sterling LLP

USD LIBOR panel has ceased…what now?

June 30th has passed and one-, three- and six-month USD LIBOR settings have ceased to be published. As confirmed by the FCA on 3 April 2023, the ICE Benchmark Administration (IBA) has begun publishing non-representative...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

Latest CFTC Action on LIBOR Transition

In its last regulatory action for 2022, on December 23, the U.S. Commodity Futures Trading Commission (“CFTC”) published its staff no-action letter No. 22-21 (“NAL”) allowing commodity brokers – Futures Commission Merchants...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

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2022

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

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

Cadwalader, Wickersham & Taft LLP

London, Here We Come - June 2022 | Issue No. 181 - LSTA Publishes New Forms of Term SOFR Amendments

The LIBOR transition process continues to roll along. New transactions are (mostly) being closed without using LIBOR any more, and many legacy transactions are naturally transitioning when refinanced or renewed this year....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

Dechert LLP

SOFR:  The Face That Launched a Thousand Ships Was Photo-Shopped!

Dechert LLP on

Why I’m bothering to write about SOFR transition at this point is a bit of a mystery.  Hasn’t this topic now finally exhausted both our energy and interest?  Oh, and a European war is being fought as I write which, to say the...more

Cadwalader, Wickersham & Taft LLP

Be Bold - January 2022 | Issue No. 159 - Four Bold Predictions for 2022

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

Shearman & Sterling LLP

UK Conduct Regulator's Rules for Use of Synthetic Sterling and Yen LIBOR Enter Into Force

The U.K. Financial Conduct Authority's new rules permitting legacy use of certain synthetic sterling and yen LIBOR settings enter into force today. The FCA has published its final notice confirming that ICE Benchmark...more

Cadwalader, Wickersham & Taft LLP

Total Recall July 2021 | Issue No. 134 - LIBOR Transition Update: SOFR Spotted in the Wild

We have been talking about the LIBOR transition a lot lately, whether here in FFF, amending deals to contemplate the benchmark transition or working with our clients to determine the best way to address the move away from...more

K&L Gates LLP

The End is Nigh-Bor For Good Old LIBOR: Important Transition Dates as New York Legislative Fix Becomes Law

K&L Gates LLP on

This is an update on recent events in the cessation of the London Inter-bank Offered Rate (LIBOR): InterContinental Benchmark Exchange (ICE), the organization that administers and announces LIBOR, and the United Kingdom’s...more

Mayer Brown Free Writings + Perspectives

The New York LIBOR Legislative Solution Becomes Law

On April 7, 2021, the proposed New York “legislative solution” for legacy USD LIBOR contracts became Article 18-C of the New York General Obligations Law. Article 18-C is primarily aimed at USD LIBOR contracts, securities or...more

Sullivan & Worcester

And Spring Heralds SONIA….and Alternative Rates

Sullivan & Worcester on

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

Latham & Watkins LLP

FCA Confirms Dates for Cessation of LIBOR Benchmarks

Latham & Watkins LLP on

On 5 March 2021, the UK’s Financial Conduct Authority (FCA) formally announced the dates for the cessation of all London Interbank Offered Rate (LIBOR) benchmark settings currently published by ICE Benchmark Administration...more

Kramer Levin Naftalis & Frankel LLP

The End of LIBOR

On March 5, 2021, the ICE Benchmark Administration (IBA), UK Financial Conduct Authority (FCA) and International Swaps and Derivatives Association (ISDA) made important announcements regarding the timelines of the cessations...more

Eversheds Sutherland (US) LLP

FCA announcement triggers LIBOR endgame

On 5 March 2021, the UK Financial Conduct Authority (FCA) and the administrator of LIBOR, ICE Benchmark Administration (IBA) each made important announcements for parties to instruments or other contracts referencing LIBOR. ...more

Lowndes

ARRC and ISDA Cement the Long-Anticipated Shift Away from USD LIBOR

Lowndes on

On Friday, the end-date for the long-anticipated shift away from USD LIBOR was finally cemented, and this morning, the Alternative Reference Rates Committee (ARRC) confirmed that a “Benchmark Transition Event” has occurred...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2021

HUD, VA, and USDA Coordinate Extensions of COVID-19 Relief for Homeowners - The U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Veterans Affairs (VA), and the U.S. Department of Agriculture...more

Dechert LLP

Dechert on LIBOR - A New Year Special

Dechert LLP on

2020 was a busy year for global benchmark transition, and the coronavirus pandemic did little to slow the pace. The end of 2020 saw an unexpected development that caused the market to pause – the potential delay of the...more

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