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Stay of Execution Proposed for USD LIBOR

ICE Benchmark Administration Limited ("IBA") upends market expectations by announcing a consultation on an 18-month extension for most tenors of USD LIBOR. IBA announced on November 30, 2020, that it would launch a market...more

FCA Consultation on New Benchmark Powers Highlights Ongoing Discussions Regarding USD LIBOR

The Situation: On the same day that the ICE Benchmark Administration ("IBA") launched a consultation on its intention to cease publishing euro, sterling, Swiss franc, and yen LIBOR at year-end 2021, the UK Financial Conduct...more

ISDA's IBOR Supplement and Protocol: Background, Operation, Prognosis

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

Back to the Well: ARRC Seeks Market Input on Simplifying Spread Adjustment Calculation

The Development: The Alternative Reference Rates Committee ("ARRC") announced the results of its market consultation on the "spread adjustment" calculation for the LIBOR/SOFR transition on May 6, 2020, but found it necessary...more

ARRC Published Recommended LIBOR Transition Language For Residential Adjustable Rate Mortgages - The ARRC's recommended language...

Last Friday, the Alternative Reference Rates Committee ("ARRC") published its recommended language to address LIBOR's probable cessation after 2021 in newly issued residential adjustable rate mortgages ("ARMs"). Minutes...more

ISDA Announces Results of "Final Parameters" Consultation for LIBOR Transition - A two business-day "lag" period and five-year...

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

ISDA Pre-Cessation Trigger Consultation on LIBOR Renders Inconclusive Verdict

The Situation: The International Swaps and Derivatives Association ("ISDA") is in the midst of consulting the market on a wide variety of issues to develop "triggers" and "fallbacks" related to LIBOR cessation. Thus far,...more

Mandatory Summer Reading: SEC Staff Issues Rare Joint Statement on LIBOR Transition

The Situation: The Staffs of the Divisions of Corporation Finance, Investment Management and Trading and Markets ("Divisions") of the U.S. Securities and Exchange Commission ("SEC") and its Office of the Chief Accountant...more

Bank of England Publishes Discussion Paper on Risk Management Systems for Collateral Referencing LIBOR

The Situation: The LIBOR manipulation scandal and vanishing liquidity in the London inter-bank market for time deposits led the Financial Conduct Authority ("FCA") to announce that at the end of 2021, banks would no longer be...more

ARRC Publishes Final LIBOR Transition Recommendations for Securitizations and Bilateral Business Loans

Financial institutions around the world are addressing the probable cessation of "LIBOR" interest rates before 2022 by, among other things, developing language designed to substitute an industry-approved successor rate (most...more

ARRC Publishes Final LIBOR Transition Recommendations for Floating Rate Notes and Syndicated Business Loans

The Situation: Financial industries around the world are addressing the probable cessation of LIBOR interest rates before 2022 by, among other things, developing language designed to substitute an industry-approved successor...more

Compare and Contrast: SFIG's and ARRC's Differing Approaches to Benchmark Transition in Securitizations

The Situation: SFIG's LIBOR Task Force has released the first of a planned series of "green papers" on benchmark transition in the US securitization market. The Result: The Green Paper contains proposed recommendations...more

ARRC Releases Market Consultations for the Securitization and Bilateral Loan Sectors

The Situation: The Alternative Reference Rates Committee ("ARRC") released market consultations on the securitization and bilateral loan markets on December 7, 2018, concerning potential paths forward for benchmark (e.g.,...more

ISDA Publishes Results of Benchmark Fallbacks Consultation as Sunset Looms for LIBOR

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

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