On 12 March 2020, the FCA issued a statement on how it would announce LIBOR contractual triggers.

The statement provides that:

  • due to the agreement the FCA has with LIBOR panel banks to remain on the LIBOR panels until end 2021, the regulator does not expect LIBOR to cease or become non-representative before end 2021;
  • markets need to be prepared for potential announcements that some or all LIBOR settings will cease after end 2021 or that the FCA finds that they are no longer going to be representative, after end 2021. These announcements may be necessary because the regulator is given notice of the departure of panel banks; and
  • announcements could be made before end-2021, even if the cessation or loss of representative status would not occur until the panel banks had left at the end-2021 or another applicable date of panel bank departure thereafter.

For both scenarios mentioned above, the FCA announcement will:

  • be made via the Regulatory News Service, at the same time as, or very shortly followed by, a posting of a fuller statement on the FCA website;
  • be clear that it is being made in the awareness that it will engage certain contractual triggers that are activated by pre-cessation or cessation announcements made by the regulator;
  • be clear about the LIBOR currencies and tenors it relates to; and
  • include the date of cessation, or, if applicable, date from which the relevant LIBOR settings are not going to be representative.