Transfer of Power: Everything You Didn’t Know About Presidential Transitions with Dr. Terry Sullivan Executive Director of the White House Transition Project: On Record PR
Videocast: Asset management regulation in 2020 videocast series – Regulators step up pressure to implement LIBOR transition plans
Episode 9: Optimizing Value in a Marital Business Divorce: Interview with Ladd Hirsch
This article summarizes the significant problems with the LIBOR transition in the US as compared to the UK (and the rest of the world). This summary is based upon the keynote speech at the United Kingdom Financial Conduct...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
On March 5, 2021, the ICE Benchmark Administration (the “IBA”) issued feedback that it had completed the consultation with LIBOR panel banks that it began in December 2020, and stated that it will be unable to publish certain...more
The United Kingdom’s Financial Conduct Authority announced the future cessation and loss of representativeness of worldwide LIBOR rates. Potential Detrimental Developments - Recent Events - On Friday, March 5,...more
In recent weeks, U.S. banks have been receiving inquiries from the U.S. Federal Reserve System (the “Fed”) in connection with the banks’ current London Inter-Bank Offered Rate (“LIBOR”) exposure, plans for amendments which...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
Everything you need to know to be prepared for the LIBOR-SOFR transition. What to Know - ed that the US Dollar (USD) London Interbank Offered Rate (LIBOR) be replaced by the Secured Overnight Financing Rate (SOFR) as a...more
On November 30, 2020, the ICE Benchmark Administration Limited (IBA), the administrator of the London Interbank Offered Rate (LIBOR), announced that it would consult on its plan to cease the publication of one-week and...more
As both lenders and borrowers in the financial industry are well aware, the Financial Conduct Authority (FCA) of the United Kingdom publicly announced in 2017 that it would no longer compel financial institutions comprising...more
For the past several years, loan market participants have been well aware of the anticipated phase-out of the London Interbank Offered Rate (“LIBOR”) as a benchmark for floating rate instruments. Based on current regulatory...more
The disruption to capital markets caused by the COVID-19 pandemic has not shifted the overall timeline of regulators and industry bodies for the replacement of US dollar LIBOR with SOFR by the end of 2021. With the expected...more
Andrew Bailey’s most recent speech on LIBOR transition (now in his new capacity as Governor of the Bank of England) likened the transition away from LIBOR to the game of cricket...more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a National Exam Program Risk Alert on June 18, 2020 (Risk Alert), which introduces an examination initiative on the upcoming...more
On July 9, the Financial Stability Board (FSB) and the Basel Committee on Banking Supervision (BCBS) published a report on the findings of surveys on supervisory issues related to LIBOR transition undertaken by the FSB, the...more
The Situation: The SEC's Office of Compliance Inspections and Examinations ("OCIE") intends to examine registrants to assess preparation for the expected discontinuation of LIBOR and the transition to alternative reference...more
In January 2020, the Office of Compliance Inspections and Examinations (OCIE) included London Interbank Offered Rate (LIBOR) preparedness as an examination program priority in its 2020 Examination Priorities (2020...more
On May 27, 2020, the US Alternative Reference Rates Committee (ARRC) published updated best practices guidance, including a summary factsheet, complete best practices guidance and a graphical timeline. ...more
On May 27, 2020, the Alternative Reference Rates Committee (“ARRC”) published recommended best practices for preparing for the end of USD LIBOR (the “Best Practices”). The Best Practices aim to provide appropriate target...more
On March 6, 2020, the Alternative Reference Rates Committee (ARRC) released its “Proposed Legislative Solution to Minimize Legal Uncertainty and Adverse Economic Impact Associated with LIBOR Transition,” which the ARRC...more
On March 6, 2020, the Alternative Reference Rates Committee (ARRC) convened by the Federal Reserve Board and the Federal Reserve Bank of New York released a proposal for New York State legislation that is intended to reduce...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
Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from the London Interbank Offered Rate (LIBOR). The New York State Department of Financial...more
The Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac) announced on Wednesday, February 5th, that they will stop accepting LIBOR-indexed adjustable-rate mortgages...more
It is widely anticipated that the London Interbank Offered Rate (“LIBOR”) will be discontinued in 2021. As LIBOR commonly is used as an index rate for both residential mortgage and consumer loans, its discontinuance has the...more
The LIBOR transition encompasses far-ranging legal issues in the investment management space. Investment managers should consider the various implications and prepare now to mitigate regulatory and litigation risks as well as...more