The Background: In 2021, the Financial Conduct Authority ("FCA") and HM Treasury began consulting on the Wholesale Markets Review (the "Review"), a broad review of the structure, functioning, and regulation of secondary...more
On June 4, 2021, the Loan Market Association (LMA) published a recommended form of its reference rate selection agreement (the Selection Agreement), which has been updated following market feedback. The Selection Agreement...more
On May 6, the LSTA published its long-awaited concept Daily SOFR and risk-free rate (RFR)-based multicurrency credit agreements (the Concept RFR Documents). The publication of these documents is a welcomed step in the...more
ISDA’s IBOR Fallbacks Supplement and Protocol came into effect today. These fallbacks, will be incorporated with immediate effect into all new derivatives contracts which incorporate the 2006 ISDA Definitions, and in all...more
Following years of consultations, ISDA published its long-awaited IBOR Fallbacks Supplement to the 2006 ISDA Definitions (the Supplement) and Protocol on October 23, 2020. The Supplement and Protocol provide a standardized...more
Significant changes are taking place to certain inter-bank offered rates (IBORs) commonly used as interest rates in derivatives and other financial contracts. In the UK, LIBOR (the London inter-bank offered rate) is expected...more
The International Swaps and Derivatives Association, Inc. ("ISDA") has finally published its long-awaited "Amendments to the 2006 ISDA Definitions to include new IBOR fallbacks" ("IBOR Supplement") and accompanying "protocol"...more
The International Swaps and Derivatives Association, Inc. (ISDA) has launched the ISDA 2020 IBOR Fallbacks Protocol - Who should read this Client Alert? If you have derivatives contracts that are linked to, or refer to,...more
The International Swaps and Derivatives Association, Inc. (ISDA) has published the ISDA 2020 IBOR Fallbacks Protocol (the IBOR Fallbacks Protocol). This client alert sets out key issues counterparties may wish to consider in...more
On October 9, 2020, ISDA announced that on October 23, 2020 it will launch (1) the IBOR Fallbacks Supplement (Supplement) to the 2006 ISDA Definitions (Definitions) and (2) the ISDA 2020 IBOR Fallbacks Protocol (Protocol)....more
The International Swaps and Derivatives Association, Inc. (ISDA) has just announced that the ISDA 2020 IBOR Fallbacks Protocol will be launched on 23 October 2020....more
The International Swaps and Derivatives Association has published the results of its consultation on fallbacks to be introduced into standard ISDA documentation based on alternative risk-free rates for EUR LIBOR and EURIBOR....more
Recent updates from the Bank of England, the New York Federal Reserve, and the International Swaps and Derivatives Association and Bloomberg in connection with publication of IBOR fallback rate adjustments should be welcomed...more
The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more
The International Securities and Derivatives Association has published a set of Frequently Asked Questions on Interbank Offered Rate Fallback Rate adjustments. The FAQs are part of ISDA's preparations for the sweeping changes...more
The Financial Stability Board has published a progress report on reforms to major interest rate benchmarks. The report provides the FSB's annual update on progress taken by the official sector and market participants to move...more
The International Swaps and Derivatives Association has launched a consultation in which it proposes to amend its standard documentation to implement fallbacks based on alternative risk-free rates for certain key Interbank...more
The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the results of its "Final Parameters" Consultation (the "Consultation") on a number of important mechanical details and specifications for...more
Following its previous two consultations, the International Swaps and Derivatives Association has launched a consultation on the proposed final parameters that will apply to alternative risk-free rates if derivatives fall...more
On May 16, the International Swaps and Derivatives Association, Inc. (“ISDA”) published two consultations in connection with the potential discontinuation of certain interbank offered rates (“IBORs”), seeking input on (i) the...more
Two new consultations seek market input on USD and other currencies and on inclusion of "non-representativeness" trigger - The International Swaps and Derivatives Association, Inc. ("ISDA") launched two additional IBOR...more
The International Swaps and Derivatives Association has published two consultation papers on fallbacks for benchmarks. The first consultation paper concerns proposed amendments to ISDA's standard documentation to implement...more
The Situation: The International Swaps and Derivatives Association, Inc. ("ISDA") has announced the preliminary results of its market consultation concerning the fallbacks rates to be relied on upon cessation of certain...more
Six months have now passed since publication of the Dechert OnPoint, LIBOR – Where Are We Now?, and in that period progress on benchmark reform and the development of alternative risk-free-rates (RFRs) has gathered pace. At a...more