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During the London InterBank Offered Rate (LIBOR) transition, and post LIBOR’s end date of June 30, 2023, the goal for all should be that (1) the effective interest rates be generally economically equivalent as a result of the...more
Regulatory Developments - Federal Reserve Announces Results From the Review of the Supervision and Regulation of SVB - On April 28, the Federal Reserve released its report analyzing SVB’s failure (Report). The Report...more
On March 15, President Biden signed, as part of a larger appropriations act, legislation known as the “Adjustable Interest Rate (LIBOR) Act,” which addresses “tough legacy” contracts that do not provide for the use of clearly...more
During 2021, we have seen action by several key legislatures to address the risk of litigation arising out of LIBOR cessation. In February 2021, the EU’s amendments to the Benchmarks Regulation entered into force, providing...more
Recent statements by LIBOR authorities in the UK have implications for benchmark fallbacks in US documents. The UK’s Financial Conduct Authority ("FCA") and ICE Benchmark Administration ("IBA") released statements1 on...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
As most market participants are aware, in 2017, the Financial Conduct Authority (FCA), a financial regulatory body in the UK, announced that LIBOR would be phased out. The announcement was made, in part, in recognition of the...more
• The Alternative Reference Rates Committee (ARRC) recently released proposed fallback language for Libor-based floating rate note (FRN) transactions in anticipation of the cessation of Libor in 2021. • The board of...more
As has been widely published in the financial services sector, the Financial Conduct Authority in the United Kingdom (FCA) has determined that banks will no longer be compelled to support the London Interbank Offered Rate...more
A practical guide to the cessation of LIBOR and the transition to a new replacement benchmark rate. Unquestionably, the London Inter-Bank Offered Rate ("LIBOR") is an integral part of nearly every type of financial product...more