News & Analysis as of

Transitional Arrangements Libor

ArentFox Schiff

LIBOR Transition Comparison: UK vs. US (Round II)

ArentFox Schiff on

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

Akin Gump Strauss Hauer & Feld LLP

Pitfalls and Issues for Lenders to Consider in Connection with LIBOR to SOFR Transition

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

King & Spalding

And So it Begins: What Recent Announcements Mean for the Future of LIBOR

King & Spalding on

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

ArentFox Schiff

The End of LIBOR: The Twilight Zone™ Edition

ArentFox Schiff on

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

King & Spalding

What Happened to My Interest Rate? Fed Intensifies Scrutiny of Lenders' SOFR Transition Efforts

King & Spalding on

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

Proskauer Rose LLP

LIBOR Update: IBA Announcement Expected

Proskauer Rose LLP on

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

ArentFox Schiff

USD LIBOR Transition Period Extended Through 2023

ArentFox Schiff on

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

Womble Bond Dickinson

LIBOR Administrator Signals the Phase-Out of LIBOR to Begin in 2022

Womble Bond Dickinson on

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

McNees Wallace & Nurick LLC

Transition From LIBOR Appears to Remain on Track (At Least for Now)

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

Proskauer Rose LLP

LIBOR Transition: Preparing for the End of LIBOR

Proskauer Rose LLP on

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

White & Case LLP

Regulators determined to keep SOFR transition on track

White & Case LLP on

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

Dechert LLP

LIBOR: Time to put your foot down

Dechert LLP on

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

Dechert LLP

SEC Publishes OCIE Risk Alert on LIBOR Transition Preparedness Examination Initiative

Dechert LLP on

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

Kramer Levin Naftalis & Frankel LLP

FSB and BCBS Report on Supervisory Issues Associated With Benchmark Transition

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

Jones Day

SEC Staff Announces Initiative on LIBOR Transition

Jones Day on

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

Kramer Levin Naftalis & Frankel LLP

OCIE’s Risk Alert on LIBOR Transition Preparedness

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

Mayer Brown Free Writings + Perspectives

US ARRC Publishes Updated Best Practices Guidance, Provides Some Detail for Certain Milestones, But Retains YE 2021 Deadline

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

Cadwalader, Wickersham & Taft LLP

ARRC Releases Best Practices for Orderly LIBOR Transition

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

Mayer Brown Free Writings + Perspectives

US ARRC Proposes a New York State Legislative “Solution” for Legacy LIBOR Contracts Without Adequate Fallbacks—But What Does It...

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

Kramer Levin Naftalis & Frankel LLP

ARRC Releases Proposal for New York State Legislation for US Dollar LIBOR Contracts

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

A&O Shearman

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

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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

Eversheds Sutherland (US) LLP

Videocast: Asset management regulation in 2020 videocast series – Regulators step up pressure to implement LIBOR transition plans

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

A&O Shearman

LIBOR Transition: Fannie Mae and Freddie Mac to Stop Accepting LIBOR, Begin Accepting SOFR

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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

Mayer Brown

Going Through Changes: Transitioning to a LIBOR-less World for Consumer Loans

Mayer Brown on

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

Morgan Lewis

The End of LIBOR: Considerations for Investment Managers

Morgan Lewis on

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

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