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Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

Digital Assets-Focused UCC Amendments Pass New York Legislature

On June 11, 2025, the New York State Senate passed a bill adopting the 2022 Amendments to the Uniform Commercial Code (UCC). The 2022 Amendments have now been passed by both houses of the New York legislature, and can be...more

Bye-bye BSBY?

Earlier this week, Bloomberg Information Services Limited (“BISL”) announced that it is seeking feedback on a proposal to cease the publication of the Bloomberg Short-Term Bank Yield Index (“BSBY”) “following a review of...more

Regulatory and Transactional Implications of Recent Moody’s Bank Ratings Downgrades

Earlier this week, Moody’s Investor Services downgraded the credit ratings of 10 regional banks and put 17 other banks under review or gave their rating a negative outlook. Notwithstanding the downgrades, most of the...more

Happy FFFourth! June 2023 - A LIBOR Commencement Speech

The London Interbank Offered Rate (LIBOR) will stop being published on the basis of panel bank quotes and will be replaced by alternative replacement rates after today. In the spirit of the season, below is the commencement...more

A LIBOR Commencement Speech

The London Interbank Offered Rate (LIBOR) will stop being published on the basis of panel bank quotes and will be replaced by alternative replacement rates after June 30, 2023. In the spirit of the season, below is the...more

ARRC Updates its Recommendations for Use of Term SOFR

The Alternative Reference Rates Committee (ARRC) announced three updates to its recommendations for the use of Term SOFR.  First, the ARRC clarified the scope of “business loans” that may be hedged with Term SOFR swaps....more

FCA Compels the Publication of ‘Synthetic’ USD LIBOR

After USD LIBOR stops being published on June 30, 2023, “synthetic” USD LIBOR will continue to be published for a limited period, according to the UK’s Financial Conduct Authority (“FCA”). The FCA said that the “synthetic”...more

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

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