News & Analysis as of

International Swaps and Derivatives Association New Guidance

Patomak Global Partners

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more

Cadwalader, Wickersham & Taft LLP

ISDA Publishes Updated General Disclosure Statement for Transactions

In 2013, the International Swaps and Derivatives Association (“ISDA”) started publishing the General Disclosure Statement for Transactions document (“General Disclosure”) with annexes containing disclosures of risks that are...more

BCLP

Watch Out For Basis Risk - Preparing and Executing LIBOR Transition in UK PPP, Infrastructure: Government Publishes Guidance

BCLP on

The Infrastructure Projects Authority (“IPA”) recently published guidance on LIBOR transition and key considerations for both UK PFI/PPP contractors and their financiers in respect of active LIBOR transition. Whilst this...more

Ballard Spahr LLP

IRS Releases Guidance on the Transition From LIBOR

Ballard Spahr LLP on

The IRS recently released helpful guidance in Revenue Procedure 2020-44 to assist the market’s transition from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (IBORs) to alternative reference...more

ArentFox Schiff

The End of Libor – Proposed Helpful Guidance for Borrowers from the Treasury Department for Tax Exempt Bond Obligors – With Some...

ArentFox Schiff on

Many conduit tax exempt revenue bonds bear interest at a floating rate, most typically a percent of USD 1-month LIBOR (here, LIBOR). Many of these transactions have been synthetically “fixed” by the conduit borrower entering...more

Moore & Van Allen PLLC

SEC Staff Issues Statement on Preparing for Impending LIBOR Transition

Moore & Van Allen PLLC on

On July 12, 2019, the U.S. Securities and Exchange Commission (SEC) joined the call to prepare for the transition away from LIBOR. The staff of several Divisions of the SEC (the Divisions of Corporation Finance (DCF),...more

Jones Day

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

Jones Day on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Final Phases of Initial Margin Requirements for Uncleared Swaps Expected to Spark Additional Margin Compliance Efforts

On July 19, 2018, the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) published a white paper entitled "Initial Margin for Non-Centrally Cleared...more

Pillsbury Winthrop Shaw Pittman LLP

LIBOR and the Transition to Risk-Free Rates

With LMA guidance being issued, LIBOR transition continues, but there is still a long way to go. Work continues on the transition to risk-free rates, but progress is slow—FCA publishes timetable and milestones. ...more

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