Navigating “the final and critical phase” of LIBOR – Senior Managers take heed

At the end of 2020, we identified the key issues to have in mind as we entered the LIBOR “endgame”: readiness; right time; right information; right rate; remaining contracts; and record keeping. The PRA and FCA have reinforced all these points in a Dear CEO letter published on 26 March 2021, which we consider in this blog post. The issues raised in this Dear CEO letter are not unexpected but are not straightforward to manage. Read more

LIBOR Discontinuation: FCA non-representativeness announcement

The FCA today made its much anticipated announcement that all LIBOR settings will either cease to be provided by any administrator or will no longer be representative: immediately after 31 December 2021, in the case of all sterling, euro, Swiss franc and Japanese yen settings, and the 1-week and 2-month US dollar settings; and immediately after 30 June 2023, in the case of the remaining US dollar settings. Read more

FSR Outlook 2021: Paving the Way Forward

We are pleased to announce the launch of FSR Outlook 2021: Paving the Way Forward. In this annual publication, we survey the regulatory landscape in 2021 and identify some themes that we expect to be at the core of regulatory priorities globally in the next 12 months. Read more

Leaving LIBOR: the ISDA 2020 IBOR Fallbacks Protocol and IBOR Supplement

With LIBOR due to disappear by end-2021, work has been underway to facilitate the transition from LIBOR and other IBORs to alternative risk free rates (or RFRs). The derivatives market has been at the forefront of the transition and is some distance further ahead than other financial markets. In particular, ISDA has recently published the 2020 IBOR Fallbacks Protocol and IBOR Fallbacks Supplement, which introduce hardwired fallbacks from IBORs to relevant RFRs for new products and legacy products. Read more